In an enforcement update published on May 24, 2019, the UK Office of Financial Sanctions Implementation, HM Treasury, reported a £10,000 penalty imposed on Travelex (UK) Ltd for breach of financial sanctions regulations. Specifically, OFSI found it likely that Travelex had knowingly breached, or had reasonable cause to suspect that it breached, a prohibition imposed by regulation 3 of the Egypt (Asset-Freezing) Regulations 2011 (S.I. 2011/887). According to OFSI, Travelex had direct, in-person contact with, and dealt with the funds of, a designated person in the UK, which allowed the designated person to use £204 of funds that ought to have been frozen.
This is the second — and the largest — penalty imposed by OFSI as part of its enforcement of financial sanctions. OFSI noted that the penalty issued against Travelex is linked to the monetary penalty against Raphaels Bank, issued in January 2019 and described here. Whilst Raphaels Bank was afforded a discount for voluntary disclosure, the absence of any such voluntary disclosure by Travelex meant no such discount was available.