European sanctions enforcement: the last two months

This blog has been live now for just over two months.

During that time and by way of recap, a number of states have provided updated enforcement statistics in that period (Finland, Switzerland, Latvia), but the period has also seen a significant volume of new enforcement activity:

New investigations:

1. 1. the UK’s FCA is investigating banks in relation to possible sanctions compliance breaches
   2. Moldova is investigating the sale of aircraft parts to Russia;
   3. Latvian authorities are investigating possible unlawful imports of Belarus timber in relation to Belarus timber;
   4. Latvia is also investigating a possible breach of the public procurement prohibition re Russian goods;
   5. an ongoing BaFin investigation into a bank;
   6. Danish investigation into the import of Russian-origin fuel from India; and
   7. four Irish investigations.

New arrests:

1. 1. three arrested in the Netherlands on suspicion of dual-use exports to Russia; and
   2. three arrested in Germany for luxury car exports.

New charges:

1. 1. the UK’s National Crime Agency has brought seven charges against an individual;
   2. three referrals for prosecution in Switzerland (here and here);
   3. two charged in Germany relating to drone exports;
   4. five charged in Finland with alleged drone exports including two companies
   5. ongoing prosecution in Germany for alleged import of Belarus timber.

New convictions or fines imposed:

1. 1. a tenth fine imposed by SECO in Switzerland;
   2. the Dutch National Bank fined a bank nearly €1.2m in Netherlands;
   3. a fine imposed in Lithuania;
   4. a fine imposed in Latvia;
   5. a conviction in Finland related to drone exports;
   6. Finland secured a conviction for breach of the travel ban on designated; persons; and
   7. confiscation of a luxury villa in France.