Why are OFSI checks and ongoing monitoring required?

Under UK financial sanctions law (Sanctions and Anti-Money Laundering Act 2018), it's prohibited to deal with funds owned by, or make funds available to, designated persons and companies on the sanctions register. Since 14 May 2025, letting agencies are "relevant firms" with mandatory OFSI reporting obligations under The Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024. Because Calmony processes payments in and out of your Griffin Bank account, you, Calmony, and Griffin all share responsibility for compliance.

The consequences of a breach

• Fine: facilitating a payment in or out to a sanctioned individual or company can result in a penalty of up to £1 million or 50% of the breach value, whichever is greater - even without knowledge of the breach.
• Criminal conviction: breaching UK financial sanctions is a criminal offence under the Sanctions and Anti-Money Laundering Act 2018, carrying a maximum penalty of up to 7 years' imprisonment, which may also result in director disqualification.

Strict liability applies: since 15 June 2022, UK sanctions breaches are strict liability offences. You can be penalised even if you didn't know someone was sanctioned - "I didn't know" is not a legal defence.

Why does Calmony check every 24 hours?

Individuals can be added to the UK Sanctions List at any time, and the register is updated daily. Someone compliant today could be designated tomorrow, and continued transactions with them would be illegal - so we screen every account every 24 hours to catch this before it happens.

Why check the account holder paying in, not just tenants?

Anyone can pay into an account, including parents paying on behalf of students, guarantors, third-party companies, or friends and relatives. Even if the tenant is monitored, the payer could be sanctioned. We check every party to a transaction because the prohibition applies to "making funds available to or for the benefit of" designated persons - not just to the named tenant.

Why don't referencing companies need this?

Referencing companies provide information services - they don't hold client money, process payments out, or receive payments in. Calmony and Griffin Bank handle actual money movement in a client bank account, which is what triggers the asset freeze prohibitions that referencing companies don't face.

What's different about Calmony and Griffin Bank?

Many banks rely on transaction monitoring systems that flag suspicious activity after the fact, alongside an expectation that customers monitor their own compliance. Once they detect a suspected match, they often freeze or close accounts immediately to eliminate their own risk exposure.

Calmony and Griffin take a different approach: daily screening identifies potential matches before transactions complete, rather than reacting once a payment has already gone through. This protects you, your landlords, Calmony, and Griffin from the consequences above, while allowing your business to keep operating without sudden account closures.

What happens if there's a match?

If we identify a potential sanctions match:

1. We'll notify you immediately.
2. You must verify the match against the full sanctions list entry.
3. If it's a "true match," you must report to OFSI and freeze the relevant funds. For OFSI reporting or queries: ofsi@hmtreasury.gov.uk.
4. If it's a false positive, document your reasoning.