From GT:

"In fact, OFSI intended to impose a much larger penalty of £300,000. However, Telia exercised its right to request that the penalty be reviewed by a government minister under Section 147 of the Policing and Crime Act 2017.

Having carried out his review, John Glen MP, Economic Secretary to the Treasury, upheld OFSI’s decision to impose a penalty but substituted the £300,000 with the lesser but still significant amount of £146,341. The nearly 50% reduction of the proposed penalty was based on information advanced by Telia which, for reasons that are not clear, was not available to OFSI at the time the original penalty was imposed but which significantly reduced the value of the breaches.

This is only the third fine imposed by OFSI since the office was established in April 2016. The previous two fines, imposed earlier this year against Raphaels Bank (£5,000) and Travelex (£10,000), respectively, pale in significance.

None of the three fines begins to compare to the enforcement activity of the well-established and longer functioning U.S. Office of Foreign Assets Control (OFAC) which has imposed a total of £1.2 billion in fines in 2019 alone."