The UK government has fined an Irish subsidiary of Apple £390,000 after it breached sanctions by making payments to a Russian app developer linked to a designated entity.
The Office of Financial Sanctions Implementation (OFSI) fined Apple Distribution International, Apple’s Ireland-based subsidiary, £390,000 for making two payments totalling more than £635,000 to a sanctioned Russian entity through the App Store in 2022.
This is the first time a UK sanctions regulator has penalised a major technology platform for processing developer payments to a sanctioned entity.
It establishes explicitly that app store payment flows fall within OFSI’s enforcement scope and that the companies operating those platforms bear compliance obligations that extend to knowing who their developers are, who owns them, and when that ownership changes.
The payments were made to Okko, a Russian video streaming service. Okko had been owned by Sberbank, Russia’s largest bank and one of the first financial institutions sanctioned by Western governments after the invasion of Ukraine in February 2022.
In May 2022, Sberbank sold Okko, along with several other digital assets, to a company called JSC New Opportunities, a Moscow-based entity created on 24 March 2022 with 10,000 roubles (approximately $175) in authorised capital.
Its sole registered owner, Tatiana Portnykh, a former stock-transfer agency representative, also controlled four similar shell companies created around the same time. The Foundation for the Defense of Democracies described the transaction as an apparent attempt to evade sanctions.
The UK sanctioned JSC New Opportunities in June 2022. Apple Distribution International made two payments to Okko in June and July 2022, totalling £635,618. The payments represented App Store revenue from customers purchasing Okko’s streaming services and were routed through UK banks, bringing them within OFSI’s jurisdiction.
In October 2022, Apple’s subsidiary voluntarily disclosed the payments to the regulator.
Apple said in a statement that it had identified the payments to a developer that “days earlier had become affiliated with a sanctioned entity” and had “promptly and proactively reported” the finding.
The fine was reduced from what it might otherwise have been because of the self-reporting and because Apple waived its right to appeal. OFSI confirmed that the penalty was imposed on the Irish subsidiary, not on Apple Inc. itself.
OFSI announced in January 2026 that it would double the maximum penalty for financial sanctions breaches to the greater of £2 million or the total value of the breach, and introduced a new settlement scheme with a 20 per cent discount for early resolution.
The agency also signalled a shift from reactive, disclosure-driven enforcement to proactive, intelligence-led investigations. In that context, the Apple fine looks less like an isolated case and more like a first example of a new enforcement posture.
The £390,000 penalty will not appear in Apple’s quarterly earnings. The company’s compliance team will absorb the finding, update its screening processes, and move on.
