Apple Fined £390,000 for Unauthorized £635,618 Payments to Sanctioned Russian App

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Apple has been fined £390,000 for two payments totaling £635,618 to Okko in June and July 2022 after the streaming app was sanctioned under JSC New Opportunities. The penalty was reduced from £600,000 following Apple’s voluntary disclosure, highlighting gaps in its sanctions compliance processes.

1. OFSI Imposes £390,000 Penalty on Apple Distribution Limited

Apple Distribution Limited received a £390,000 penalty from the Office of Financial Sanctions Implementation after making two payments totaling £635,618 to Okko on June 30 and July 28, 2022, once the streaming app had been sanctioned under JSC New Opportunities.

2. Payment Timeline and Sanctions Context

Okko was originally owned by sanctioned Sberbank, leading Apple to make over £1.2 million in April 2022 before stricter liability rules. The later June payment fell within a narrow cancellation window, but the July transfer proceeded without detection of the app’s new sanctioned status.

3. Compliance Shortcomings Identified

The watchdog found Apple relied on self-certification by app developers and third-party due diligence rather than proactively requesting ownership information. This approach failed to flag Okko’s sanction affiliation and allowed the breach payments to occur prior to updated compliance protocols.

4. Penalty Reduction and Next Steps

Apple’s voluntary disclosure of the breach and entry into settlement talks reduced the fine from £600,000 to £390,000. The company has pledged to strengthen its sanctions compliance procedures to align with industry standards and prevent future violations.

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