Supplier payment breached sanctions: what now?
Pause further payments and related dealings, contact a UK sanctions solicitor and preserve transaction and ownership records. Check mandatory reporting and voluntary disclosure promptly, then prepare an accurate account for OFSI. Ask Cambridge China Bridge to help gather supplier records from China.
Pause related activity and escalate
Put further supplier payments, new orders and related release instructions on hold while the concern is assessed. Tell your finance and purchasing leads, your sourcing provider and the bank handling the payment. Ask the bank to confirm whether the transfer is pending, completed, blocked or returned, and preserve its response.
Do not try a different beneficiary, intermediary or payment route to get the order moving. Ask a UK sanctions solicitor how to handle pending transfers, goods, refunds and communications. Keep the incident response separate from routine sanctions checks before buying.
Give your solicitor the facts
Explain what triggered the concern, when you discovered it and what happened before and after payment. Supply the supplier’s legal name, the actual beneficiary, intermediaries and any suspected ownership connection. Separate confirmed facts, possible matches and missing information; a similar name should be investigated rather than treated as a final conclusion.
Ask the solicitor to assess the payment as it happened, the applicable sanctions position and what activity can safely continue. Licences cannot be issued retrospectively. Do not assume that applying now resolves an earlier payment.
Preserve payment and ownership evidence
Keep original contracts, purchase orders, invoices, payment instructions, bank confirmations and messages, including changes to beneficiary details. Record payment value, currency, dates, transaction references and the parties involved. Preserve the screening results used at the time alongside later checks, with their sources and dates.
Gather company identifiers, registration documents, ownership charts, shareholder records and evidence of who directs the business. Include the source and date of each document and any gaps or contradictions. Ask Cambridge China Bridge’s staff in China to help collect supplier records, while leaving the sanctions assessment to your specialist adviser.
Check reporting and prepare the OFSI submission
Some financial sanctions breaches must be reported to OFSI. Ask your solicitor whether your business has a mandatory reporting obligation and whether to make a voluntary self-disclosure. OFSI says suspected breaches should be reported as soon as practicable. Do not wait for a perfect evidence file before discussing an initial report and later follow-up.
Use the OFSI financial sanctions suspected breach reporting process. Prepare a factual narrative and supporting documents before opening the form: explain the transaction, parties, discovery, uncertainties and steps taken. Have your adviser check the account, retain what you submit and save the acknowledgement and reference.
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Control any restart
Keep a written incident log showing who paused activity, what was checked, advice received, reports made and decisions still pending. Agree who can authorise a restart and what evidence they need. A supplier reassurance or a successful transfer should not be your internal clearance decision.
Review how the concern escaped your checks: beneficiary changes, missing ownership records, screening gaps or unclear approval responsibilities. Use order and payment approval controls to update the purchasing workflow, and brief anyone handling the next payment.
Frequently asked questions
Should I stop paying the supplier?
Pause further payments and related instructions while a sanctions solicitor assesses the concern. Ask your bank for the transfer’s status and preserve its written response.
Do I have to report a suspected breach to OFSI?
Some breaches must be reported. Ask a sanctions solicitor to check your business’s obligation and voluntary disclosure options promptly. OFSI says suspected breaches should be reported as soon as practicable.
Can I get a licence after paying the supplier?
Licences cannot be issued retrospectively. Get specialist advice about the completed payment and any planned future activity.
What evidence should I keep?
Keep contracts, invoices, payment instructions, bank records, messages, screening results and ownership documents. Record sources, dates, changes and gaps; preserve originals.