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In April 2025, the United Kingdom secured its first-ever criminal conviction for a breach of Russian sanctions — a milestone in the global enforcement landscape. But beneath the headline lies a far more pressing narrative: how a sanctioned Politically Exposed Person (PEP) was able to enter the UK, open a bank account, and launder funds through mainstream financial and non-financial institutions without detection.
The conviction of Dmitrii Ovsiannikov — a former Russian Deputy Minister and ex-Governor of Sevastopol — should be a sobering moment for every legal, compliance, and risk leader. This wasn’t a complex crypto scheme or an advanced cyber intrusion. It was an almost banal series of oversights and procedural failures, with one common denominator: the absence of rigorous Enhanced Due Diligence (EDD).
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The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
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