At the time both payments were executed in June and July 2022, Okko was subject to UK sanctions following Russia’s invasion of Ukraine.
OFSI said that Apple had relied on corporate affiliates to implement payment processes, sanctions screening and due diligence measures. Apple said in response to the fine that it takes “sanctions compliance extremely seriously".
“After identifying two payments to a developer that days earlier had become affiliated with a sanctioned entity, we promptly and proactively reported our finding to the UK government,” it added.
OFSI said that companies are ultimately responsible for “ensuring compliance with financial sanctions". Third-party compliance firms are “often invaluable in supporting firms, particularly those with large and complex customer bases", OFSI said in its statement.
See also: Trump announces three-day ceasefire between Russia, Ukraine
On March 20, OFSI fined the law firm Herbert Smith Freehills £465,000 over Russian sanctions breaches. Their Moscow office made six payments worth £3.9 million to banks under UK asset freeze orders, the agency said.
“Whilst there is no suggestion that Apple sought to circumvent sanctions, it is apparent that they were slow to update their payment systems and failed to spot several red flags surrounding the payments,” said Neil Dooley, a lawyer at Quillon Law not involved in the case.
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