The UK’s HMRC has today announced the imposition of compound penalties on four UK exporters. Those companies were not named.
Little information is provided but the exports were all either dual-use goods or military goods.
The compound penalties which were imposed between November and December 2022, were:
An individual has today been convicted of exporting €11,000 in physical currency from Germany to Russia in breach of Art 5(i)1 of EU Regulation 833/2014.
The individual asserted that he was carrying the currency for the purposes of receiving dental treatment in Kaliningrad.
The judgment takes the view that the exception permitting some cash to be carried “should … be interpreted narrowly”, and that the Commission’s FAQs are a means of discerning the intention of the legislator.
He was fined €4,500 and the balance of the cash above the €500 threshold was confiscated.
It is being reported that the Danish Business Authority has referred two cases to the police for potential further action.
This is further to our earlier post relating to the commencement of the investigations.
Both cases relate to the continuation of operations by designated Russian organisations in Denmark.
These two police investigations add the the 12 already known to have been commenced (see our earlier post).
The Spanish Guardia Civil has today arrested a British national in response to an extradition request by the US authorities.
The man, Richard Masters, is alleged to have assisted in the contravention of sanctions as part of the management and operation of the yacht the M/Y Tango on behalf of sanctioned Russian Viktor Vekselberg.
The yacht has also been seized.
It is being reported that the Danish Business Authority is investigating whether the so-called “Russia House” in Copenhagen, which is a designated person under the EU’s sanctions has been breaching the asset freeze imposed upon it.
This follows an earlier report that the Danish Business Authority was also investigating possible breaches by Rossotrudnichestvo.
The French Ministry of Finance has today announced an investigation into the sanctions compliance practices of estate agencies in the region of Alpes-Maritimes.
A preliminary investigation is said to have revealed that 60% were not conducting sanctions screening.
The UK’s Financial Conduct Authority has issued a Final Notice to Al Rayan Bank PLC in relation to its failings with customer due diligence, including a lack of due diligence documentation for customers linked to sanctioned countries, or the lack of appropriate enhanced due diligence.
The bank was fined £4,023,600.
On an appeal from an earlier conviction for transferring €245 in breach of the EU’s sanctions against ISIS and Al Qaeda, the Dutch Supreme Court has ruled that a conviction does not require a showing of any intention to breach the sanctions.
Completion of the transfer itself is enough to complete the offence.
The UK’s Financial Conduct Authority has issued a Final Notice against Guaranty Trust Bank (UK) Limited.
The fine was £7,671,800.
The reported failings include a lack of screening against OFSI’s Consolidated List despite policies and procedures requiring such screening. Thousands of accounts had also been established in a way that screening was only done at onboarding and not periodically. Further 90% of resolved sanctions “hits” did not include information or documents demonstrating the basis for the resolution.
Latvia’s Intelligence Services (the VDD) have arrested a Latvian national, reported as Marat Kasem.
The alleged offence is the provision of “economic resources” to a designated person, or an asset owned or controlled by such a person.
The designated person is Dmitry Kiselev, who is the Director General of Rossiya Segodnya which in turn owns a number of broadcast channels including Sputnik and Baltnews.
Mr Kasem is alleged to have provided the “economic resources” by way of being employed by these channels in Lithuania.
