Johnson Matthey was also credited for improving its compliance function after the breaches had been reported. OFSI has engaged in enforcement action against companies every year since its first administered fine in January 2019, the Tracerco fine being its seventh enforcement action overall. Of these actions, however, only one has resulted in a fine of more than six figures, indicating that OFSI continues to utilise its powers most frequently on discrete financial sanctions breaches. Given the breadth of new sanctions and numerous designations implemented this year in relation to Russia's aggression towards Ukraine, many continue to speculate as to whether the agency will be presented with an opportunity to engage in another large enforcement action, akin to its action against Standard Chartered Bank in 2020, where a £20.47 million total fine was imposed.