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.

UK’s OFSI imposes fine for breach of Syrian sanctions

OFSI has today announced a civil penalty of £15,000 against Tracerco Limited for a breach of the EU’s Syrian sanctions.

OFSI’s Penalty Notice is available here.

The breaches related to airline tickets valued at £2,956.43 purchased for a Tracerco employee through a travel agency. The airline in question, however, was Syrian Arab Airlines which is designated under the EU’s sanctions.

OFSI, therefore, concluded that purchasing the tickets amounted to making funds available to a designated person. OFSI also commented, in relation to the requirement that it showed Tracerco either knew or had reasonable grounds to suspect that the transactions would breach the regulations, that operating in the region was sufficient to satisfy this requirement.

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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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