The Office of Financial Sanctions Implementation (OFSI) has imposed a £165,000 monetary penalty on Deutsche Bank AG London Branch under section 146 of the Policing and Crime Act 2017 for breaches of the Russia (Sanctions) (EU Exit) Regulations 2019, SI/2019/855. The penalty relates to two payments totalling £635,618.75 processed in June and July 2022 to Okko LLC, a company wholly owned by designated person JSC New Opportunities. OFSI determined that the payments violated Russia (Sanctions) (EU Exit) Regulations 2019, SI/2019/855, reg 12, which prohibits funds from being made available to persons owned or controlled by designated persons. The breaches arose after DBLB’s third-party screening vendor failed to include ownership data for Okko, meaning sanctions alerts were not generated during transaction screening. OFSI classified the matter as ‘serious’ and applied a 45% reduction to a baseline penalty of £300,000 in recognition of DBLB’s voluntary disclosure on 20 September 2022 and its settlement under OFSI’s new enforcement framework introduced on 9 February 2026. The matter was resolved through settlement discussions that commenced on 4 March 2026 under transitional arrangements, with DBLB agreeing to pay the penalty and waive its rights to ministerial review and tribunal appeal.