April 2019 – European Sanctions Enforcement

April 9, 2019March 15, 2024 by Mark Handley

UK – FCA imposes fine of £102m

The UK’s Financial Conduct Authority has issued a Decision Notice against Standard Chartered Bank including a fine of £102,163,200.

The fine related to KYC failings in general, with a focus on failure to conduct customer due diligence even in situations where sanctions red flags were evident. The FCA noted a lack of financial crime risk, and concerns as to the quality of the advice being given.

A particular focus were the UAE branches of the bank, and also export financing in relation to the export of military goods.

April 8, 2019January 11, 2024 by Mark Handley

France – banking regulator finds breaches but does not fine

The Sanctions Commission of the French Banking Regulator (the ACPR) has published its decision from disciplinary proceedings against Raguram International.

Between 2015 and 2017, Raguram had failed to conduct KYC on its customers and failed to incorporate the lists of Eu sanctioned persons into its systems and controls framework.

At the time Raguram had not recognised that its controls environment was defective, but it had subsequently implemented stricter policies and procedures and purchased a compliance solution.

As a result of these steps no fine was imposed.

April 3, 2019March 15, 2024 by Mark Handley

UK – HMRC fines exporter £82,152.33

The UK’s HMRC has today announced that it has fined a UK exporter £82,152.33 for the unlicensed exports of military goods.

The identity of the exporter, and of the destination for the goods, were not published.

April 3, 2019January 11, 2024 by Mark Handley

Germany – company fined €11 million and three managers sentenced for unlicensed exports

Three managers of Sig Sauer, the arms manufacturer have been convicted (after guilty pleas) of the unlicensed export of small arms to Colombia. See our earlier post.

One manager was fined €600,000 and given an 18-month suspended prison sentence. Another was fined given a 10-month suspended sentence and also fined €600,000. A third was fined €60,000 and given a 10-month suspended sentence.

The company itself was fined €11 million.

April 1, 2019February 26, 2024 by Mark Handley

Netherlands – individual convicted for transfers to ISIS family members

The Dutch authorities have obtained the conviction of an individual for making financial transfers to two family members in breach of the EU’s sanctions against ISIS.

Five transfers were made in total with the largest being €3,500.

The man was given a suspended 100 day prison sentence with a 2 year probation period and 240 hours of community service.