U.K. Drops Anonymity for Sanctions Settlements in a Broader Transparency Push

For years, companies that reached compound settlements with the U.K. for violating sanctions only had to absorb quiet, private fines. 

But starting with last month’s surprise naming of the Scottish energy firm Petrofac Facilities Management Limited (PFML) for serious violations of Russia sanctions, that veil of anonymity for U.K. corporate offenders has now dropped.

“Naming those involved brings us into line with other enforcement partners whilst sending a clear message on the consequences of breaching sanctions rules,” Edwige Hill, a top HM Revenue and Customs (HMRC) official, said in a news release announcing the settlement.

What it means: The reputational risks for violating U.K. sanctions just got higher.

And HMRC is signaling more transparency moves to come.

The case: PFML’s violations occurred in 2022 and 2023, while the Aberdeen-based company was drawing down its Russia operations. HMRC found that the business transferred controlled industrial goods to Russian-linked entities while continuing to offer technical services for those items.

PFML mitigated its penalty by voluntarily disclosing its violations and by fully cooperating during the investigation. The two sides’ final compound settlement — which HMRC can offer as a formal, negotiated alternative before a trial — amounted to £569,157 (about $765,000).

• But the sanctions-violation case itself wasn’t ground-breaking … until the government named PFML in announcing it.

Key line: “Where appropriate,” it said in its news release, “HMRC will now include naming as a condition when offering a compound settlement for strategic export and sanctions offences.” 

A culture shift: Days after the PFML announcement, HMRC published a sanctions enforcement technical note on the 2025/2026 financial year — and confirmed the naming was part of a shift toward greater transparency. 

• Most notably: The department announced plans to “seek new legal powers” over the next financial year to strengthen its ability to “publish details of companies that agree a compound settlement for strategic export and sanctions offences.”
• The new approach, HMRC explained, is designed to increase consistency across trade sanction enforcement functions. 

Together, these back-to-back developments signal that the U.K. government is leveraging corporate reputational risk as a primary deterrent, fundamentally shaping how corporate boards must weigh the risks of non-compliance.

Inside the numbers: HMRC disclosed in its technical note that it recorded only one compound settlement (in May 2025) under its Russia regulations in the last financial year, totaling £1,160,725.67 (just north of $1.5 million). 

But because HMRC operates strictly on the criminal-prosecution track, unlike the U.K.’s other sanctions-enforcement offices, its threshold for sanctions-violation cases is higher, which means each case takes time. And that last financial year was an outlier, too.

• Since the 2022 Ukraine invasion, HMRC more typically has had four to six settlements per year across export controls and sanctions. 
• Several months before the May 2025 case, notably, HMRC pulled in £3.6 million ($4.8 million) across two settlements for exports of military goods.

The bottom line: By moving away from anonymity, HMRC is aligning its trade enforcement strategy with the high-stakes, public-exposure models used by the U.S. Bureau of Industry and Security and the U.K.’s own Office of Financial Sanctions Implementation.

For other corporate actors, that makes the PFML case a loud warning shot.

Read more from The Brief:

• A U.K. Firm Arranged a $200 Payment from a Russian Airline. It Led to a £1 Million Fine.
• One European Chip Keeps Turning Up in Russian Drones. A Chain Through China Could Be How.
• The U.K. Fined Bank of Scotland for Violating Russia Sanctions. Here’s What Went Wrong.