OFSI Imposed a £1 Million Penalty on Sabre: Invoicing a Designated Person and Circumvention of Sanctions

On 26 May 2026, the UK Office of Financial Sanctions Implementation (OFSI) imposed a penalty of £1,000,920 on Sabre Global Technologies Limited (“Sabre”) for breaches of the UK’s Russia sanctions regime.

Sabre provides Global Distribution System (“GDS”) services to participants in the travel industry. Its agreement with Ural Airlines had been in place since 2007 and had been renewed several times. Following the airline’s designation under the UK Russia sanctions regime in May 2022, Sabre continued to provide access to the GDS until December 2022. The company also issued invoices for services rendered and attempted to recover outstanding debts after payments had been blocked by UK banks. Sabre subsequently decided not to renew the agreement.

The Sabre case is of particular interest as it marks the first enforcement action by OFSI for a breach of the prohibition on circumvention. In addition, the £1 million penalty is the largest fine imposed by OFSI for violations of the Russia sanctions regime since 2022. The decision demonstrates OFSI’s willingness to adopt a broad interpretation of certain prohibitions contained in the Russia (Sanctions) (EU Exit) Regulations 2019 and to take a strict approach to attempts to circumvent sanctions restrictions.

Read more about OFSI’s approach to the qualification of sanctions breaches in the article prepared by VERBA LEGAL’s Sanctions Practice.