First UK Sanction (OFSI) monetary penalty On 21 January 2019, OFSI imposed its first monetary penalty. The penalty is £5,000 on Raphaels Bank in the UK for violating EU Egypt sanctions, namely dealing with £200 in funds belonging to a designated person. OFSI reduced the penalty by 50% from £10,000 because Raphaels Banks itself disclosed […]

Summary The recent financial penalty imposed on R. Raphael & Sons Plc (“Raphaels”) by the Prudential Regulatory Authority (“PRA”) underlines the importance of having proper and formalised outsourcing arrangements in place with service providers (even where these are intra-group). Although authorised financial institutions may outsource important operational functions, the responsibility to comply with regulation will […]