On 30 September 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) announced a monetary penalty of £152,750 against Colorcon Limited, a UK pharmaceutical supplier, for breaching Russia sanctions.

Colorcon’s Moscow representative office made payments between March and December 2022 to employees and service providers whose accounts were held at designated Russian banks – including Alfa Bank, Promsvyazbank, Sberbank and VTB Bank. While some payments could have been covered by a General Licence, Colorcon failed to meet the necessary reporting requirements.

OFSI highlighted several compliance failures:

• Colorcon had operated in Russia for over 15 years, yet its sanctions controls did not reflect this elevated risk.
• Payments to employees and service providers were not screened for sanctions exposure.
• The company assumed its bank would screen for UK sanctions, despite never confirming this.

Key takeaways:

• Risk exposure matters: Companies operating in high-risk jurisdictions must tailor their sanctions compliance programmes accordingly.
• Sanctions apply across the value chain: Employees, agents, brokers and service providers can all pose sanctions risks.
• Compliance cannot be outsourced: If a third party gets it wrong, your company is still liable.

📄 Read the full penalty notice

Need help navigating sanctions risk?
I help companies build practical, risk-based compliance programmes that work across jurisdictions and value chains. If you’re unsure whether your controls are fit for purpose, get in touch or explore other posts on fairgreensanctions.com for insights and guidance.