News release

Sanctions enforcement update

06 February 2026

The Office of Financial Sanctions Implementation (OFSI) has fined Bank of Scotland Plc £160,000 after a designated person was able to open an account due to sanctions screening failures. The decision sits within a wider notice concerning Lloyds Banking Group, with responsibility attributed to Bank of Scotland Plc.

This acts as a reminder for law firms of what to consider when properly screening clients.

Name-matching matters

A sanctions search was carried out but failed to identify the individual due to variations in how Russian Cyrillic names are transliterated into the Latin alphabet. This highlights the importance of fuzzy matching when screening against the UK Sanctions List and ensuring any electronic verification tools support this.

Risk-based expectations apply

While sanctions operate under a strict liability regime, OFSI noted that firms with greater sanctions exposure should take proportionate steps to enhance their screening arrangements, even where commercial screening tools are not mandatory.

Avoid assumptions

The individual was a British citizen using a British passport. This reinforces that sanctions risk is not always obvious and should not be assessed based on assumptions or stereotypes.

Further resources

• Watch our sanctions webinar with Simon Buck, AML Regulatory and Suzie Ogilvy, a compliance professional and Partner Consultant in Ogiro Risk.
• Read our latest guidance on complying with the UK sanctions regime.