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OFSI Imposes £390,000 Penalty on Apple Subsidiary for Russian Sanctions Breaches: Key Compliance Takeaways

By Dj Wolff, Sophie Davis & Nicola Phillips on April 14, 2026
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The UK’s Office of Financial Sanctions Implementation (OFSI) has published details of a £390,000 penalty it imposed on ADI, an Irish subsidiary of Apple Inc., on 19 March 2026. The penalty relates to two payments totalling approximately £635,000 made in 2022 to Okko LLC, a sanctioned Russian app developer, for App Store revenue. Although the underlying facts are relatively simple, there are several interesting takeaways from OFSI’s penalty notice.

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Photo of Dj Wolff Dj Wolff
Read more about Dj WolffEmail
Photo of Sophie Davis Sophie Davis

Sophie Davis is a counsel in Crowell’s London office and advises clients on a range of sanctions, export controls, and trade compliance matters. Sophie has particular experience advising multinational corporations and financial institutions on how to comply with rapidly evolving trade and financial

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Sophie Davis is a counsel in Crowell’s London office and advises clients on a range of sanctions, export controls, and trade compliance matters. Sophie has particular experience advising multinational corporations and financial institutions on how to comply with rapidly evolving trade and financial sanctions across a range of EU and UK sanctions regimes, assisting corporate clients with complex sanctions issues arising from their continued operations in, or divestments from, Russia, and supporting clients with licensing applications and responding to investigations.

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Photo of Nicola Phillips Nicola Phillips

Nicola Phillips guides her clients in all areas of commercial litigation. From providing crisis management and legal advice to clients facing cyberattacks to pursuing injunctive relief for victims of fraud, Nicola’s practice has a strong focus on urgent and critical support.

Nicola has

…

Nicola Phillips guides her clients in all areas of commercial litigation. From providing crisis management and legal advice to clients facing cyberattacks to pursuing injunctive relief for victims of fraud, Nicola’s practice has a strong focus on urgent and critical support.

Nicola has a diverse practice, advising on all aspects of civil litigation, and vast experience with high court litigation as well as alternative dispute resolution. She manages large compliance investigations and has experience acting for both regulators and large financial institutions responding to governmental enforcement enquiries. Nicola also has significant experience with large, complex civil frauds and regularly obtains injunctive relief to assist with asset preservation. Her other practice areas include asset-based lending, trade finance, infrastructure, energy, insurance, and employment-related disputes.

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  • Posted in:
    Banking, Finance and Securities
  • Blog:
    International Trade Law
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

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