On 10 November 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) issued a £160,000 penalty against the Bank of Scotland Plc (Bank of Scotland).
The conduct at issue was the processing of 24 payments made in February 2023, totalling over £77,000, into and out of a personal current account held by Dmitrii Ovsyannikov, a designated person under the Russia (Sanctions) (EU Exit) Regulations 2019 (the Russia Regulations). OFSI found that (i) the processing of the 24 payments breached Regulation 11 (dealing with funds owned, held, or controlled by a designated person) and (ii) the four payments that Bank of Scotland credited to the account also breached Regulation 12 (making funds available to a designated person).