In late August 2024, the UK’s Office of Financial Sanctions Implementation (“OFSI”), a department within HM Treasury, imposed a monetary penalty of £15,000 on Integral Concierge Services Limited (“ICSL”)—a UK-based property management and concierge company—for serial breaches of the Russia (Sanctions) (EU Exit) Regulations 2019. The enforcement action followed an extensive investigation that uncovered ICSL’s involvement in facilitating payments linked to a designated individual subject...