Germany – raids investigating alleged chemical exports to Russia

It has been reported today that the German authorities have conducted raids across Germany as part of investigations into alleged exports of chemicals to Russia in breach of EU sanctions.

The raids included the premises of the companies Riol Chemie GmbH and R.R. Rhein Reserve GmbH.

It is alleged that more than 30 separate exports have taken place in the last three or so years, and that the chemicals could be used to make chemical weapons including Novichok.

Luxembourg – regulator fines bank for sanctions compliance failings

The Luxembourg financial services regulator, the CSSF, has today imposed a a fine of €145,000 on Unzer Luxembourg SA for AML and sanctions compliance failings.

The penalty notice noted that the failings, including in sanctions screening, were identified as part of an on-site inspection in 2020 and 2021, and noted that the lack of a fine took into consideration the bank’s efforts at remediation.

Luxembourg – regulator reprimands but does not fine for sanctions failings

The Luxembourg financial services regulator, the CSSF, has today imposed a reprimand on Banque J Safra Sarasin (Luxembourg) SA for AML and sanctions compliance failings.

The penalty notice noted that the failings, including in sanctions screening, were identified as part of an on-site inspection in 2019, and noted that the lack of a fine took into consideration the bank’s efforts at remediation.

Luxembourg – regulator fines banks for AML and sanctions failings

The Luxembourg financial services regulator, the CSSF, has today fined BEMO Europe Banque Privée SA €356,000 for AML and sanctions compliance failings.

The penalty notice noted that the failings, including in sanctions screening, were identified as part of an on-site inspection in 2020, and noted that the size of the fine took into consideration the bank’s efforts at remediation.

Netherlands – 18 month sentence for exports to Iran

The Dutch Supreme Court has denied an appeal against an 18-month custodial sentence against an individual for his role in  seven exports of goods to the National Iranian Gas Company which is a designated person under the EU’s sanctions.

The shipments were made via Turkey or Dubai and the defence argued in the appeal that this was not “indirectly” making economic resources available to a designated person. The Supreme Court disagreed.

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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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