Germany – investigation opened into suspected illegal chemical exports

The prosecutor’s office in Oldenburg has opened an investigation into VET Pharma Friesoythe GmbH for suspected illegal exports of a controlled chemical to Japan and United States.

The chemical is used to put down dogs, but can also be used for lethal injections. A such it is tightly regulated.

The exports are alleged to have taken place in 2017 and 2018 and to not have been properly licenced.

Germany – acquittal of charges of breaching Somalia sanctions overturned on appeal

The Higher Regional Court of Hamm has overturned on appeal an acquittal in the Münster Regional Court. The case has been remitted back to the lower courts.

The charges of breaching the EU’s Somalia sanctions relate to the alleged provision of training and technical assistance related to the manufacture, maintenance and use of arms and related materiel under a 2009 contract.

Netherlands – Dutch National Bank fines of €170,000 upheld on appeal

The District Court of Rotterdam has upheld fines of €170,000 imposed by the Dutch National Bank on a payment services provider for breaches of Dutch sanctions law and AML rules.

The appeal was largely based on arguments that the internal compliance function had adequately performed its function. The court was highly critical of this argument, noting the lack of due diligence and periodic training.

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The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

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