30 June 2022; MEMO: The United Kingdom has fined a UAE-based subsidiary of a company for violating sanctions on the Syrian regime of Bashar Al-Assad, as London grows stricter on enforcing measures and penalties for sanction violations.
The UK's Office of Financial Sanctions Implementation (OFSI) announced yesterday that it had imposed a fine of £15,000 ($18,265) on Tracerco Ltd, a company providing products and services which measure oil and gas levels. Although it operates from the United Arab Emirates, it is a subsidiary of the London-based company, Johnson Matthey PLC, a firm which deals in chemicals and sustainable technologies.
According to the OFSI, Tracerco Ltd committed the sanctions violation by making two payments to the Syrian Arab Airlines – a company sanctioned by western nations due to its direct connection to and control by the Assad regime – through an Emirati travel agency, in order to enable a company employee to fly home between May 2017 and August 2018.
The penalty would initially have been larger, but it was cut in half as the company voluntarily disclosed the violation, the British sanctions regulator said. A primary reason for the imposition of the fine, despite the fact that Tracerco Ltd indirectly and unknowingly committed the breach is due to UK's embracing of stricter standards in enforcing sanctions.
That development was announced by the regulator earlier this month, and comes in the wake of the Russian invasion of Ukraine which has pushed western nations to ramp up their enforcement of penalties for sanctions violations.
Under that stricter process, the OFSI is no longer obligated to prove that companies or individuals who violate the UK's sanctions measures were aware of their breaching of the rules. Instead, all violations – regardless of their reasons or causes – will now be treated by the same standard.