The UK government recently announced that Sabre Global Technologies Limited (“SGTL”), a UK travel technology firm, was fined £1,000,920.59 for repeated breaches of the Russia (Sanctions) (EU Exit) Regulations 2019. The Office of Financial Sanctions Implementation describes the fine as the UK’s largest penalty for Russian financial sanctions breaches since Russia’s 2022 invasion of Ukraine and as the first penalty issued by OFSI for a circumvention offense. In accordance with sanctions enforcement guidance, OFSI assessed the case as “most serious” and reported that the penalty reflects the government’s increasingly robust enforcement of the Russia sanctions regime in support of Ukraine.
The fine, which was imposed by OFSI on May 26, 2026, was imposed in connection with an SGTL contract to provide technology services to JSC Ural Airlines, a designated Russian carrier. According to the government, SGTL continued giving Ural Airlines access to its Global Distribution System for seven months after the airline was designated in 2022 and after SGTL was notified of the designation. The government further alleges that, after payments to SGTL’s UK bank were blocked for sanctions concerns, SGTL explored alternative payment routes, including asking Ural Airlines to send a test payment to a non-UK SGTL bank account so future settlements could be routed there. The government determined that SGTL’s conduct amounted to an active circumvention of UK sanctions and found that SGTL undermined the sanctions regime by providing an economic resource to a designated person. At the time of the breaches, OFSI also cited a number of compliance failures involving staffing, process, senior oversight, and sanctions-risk mitigation. OFSI did acknowledge, however, that the alleged misconduct was voluntarily disclosed to OFSI; that SGTL cooperated with OFSI’s investigation; and that the company was in the process of improving its sanctions compliance program.