UK court judgment in Equality Act sanctions discrimination case – XTX v Mazars
17 October 2025
The County Court for Central London has commented on the application of s. 44 of the UK’s Sanctions and Anti-Money Laundering Act 2018 in a discrimination case about refusal of services based on nationality – XTX Markets Ltd v Mazars LLP.
In 2022 Mazars (an accounting firm) refused services to UK-registered XTX because its ultimate beneficial owner, Dr Alexander Gerko, was a Russian national. Dr Gerko was not subject to UK sanctions, but Mazars refused to provide the services because its policy was “not to accept new clients with Russian ownership”. XTX said this was discrimination that breached the UK’s Equality Act 2010. Mazars said their actions were reasonably necessary to comply with the UK’s sanctions regime and so relied on the defence under s. 44 SAMLA. An application for summary judgment was refused in 2023.
The County Court dismissed XTX’s claim because Mazars had only refused XTX services in France and the USA. Since no services in the UK had been refused, there was no basis for a claim under the UK Equality Act. On the sanctions point the Court said:
- Had services in the UK been refused, Mazars would have discriminated against XTX on grounds of nationality since that was the reason Mazars gave XTX.
- There was no basis for saying it was reasonably necessary not to engage with XTX due to Dr Gerko’s nationality.
- There was no basis for concluding that Mazars was acting on a subjective belief that its refusal to provide services to XTX was because of a belief that it was in compliance with the sanctions regulations.
- This meant if services had been refused in the UK, the s. 44 SAMLA defence would not have applied and Mazars would have been liable for discrimination.
See our UK Judgments pages for all UK sanctions judgments.
