The German Ministry of Economy has launched an investigation into whether engineering company Bosch has made unlawful exports to Russian in breach of EU sanctions.
Romania – commencement of investigations confirmed
It has been reported that the Romanian Tax Office (ANAF) has confirmed that it has a number of ongoing investigations into possible breaches of the EU’s Russian sanctions.
No further details were reported.
France – seizure of vessel alleged to be owned by sanctioned Russian bank
The French authorities have seized the cargo ship, Baltic Leader, claimed to be owned by sanctioned Russian bank Promsvyazbank.
The vessel was headed to Russian but seized in the channel.
Germany – charges for dual-use exports to Russia
Further to our earlier post, the Federal Prosecutor’s Office has issued a press release confirming the indictment of Alexander S. on further charges relating to the export of dual-use goods to Russia in breach of EU sanctions.
The value of the exports is estimated at over €1 million.
The press release documents warning issued to Alexander S by the German authorities and his efforts to circumvent the prohibitions through falsifying documents and arranging for export from an Asian country.
Latvia – fines of €3.1m for breaches of Russian sanctions
Following raids in Riga and Tallinn by the Latvian Security Police, in close cooperation with the Estonian Internal Security Service (ISS), it was reported today that two individuals have been fined by the Latvian courts for breaching the EU’s Russian sanctions.
The breaches involved making funds available, through contracts involving broadcasting, to a designated person. The individuals (Oleg Solodov and Margus Merima) were each fined €25,000, and a further €3 million was confiscated.
Netherlands – 6 month custodial sentence
The Court of Appeal in the Hague has upheld the conviction of an individual on charges of breaching the EU sanctions against terrorist organisations.
Amongst other charges the individual was charged with making a financial transfer through intermediaries in Turkey and/or Syria to ISIS.
The man was sentenced to 9 months, of which 3 was conditional.
UK’s HMRC imposes 10 fines for export control violations
The UK’s HM Revenue and Customs has today announced the imposition of 10 compound penalties in relation to failures to comply with the UK’s export control regulations for dual-use and military goods. The fines were imposed between March and November 2021.
HMRC’s Notice to Exporters can be found here.
In line with HMRC’s standard practice the compound penalties are anonymised and of low value, with little information made available. The information provided is supplied below.
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Germany – five being investigated in relation to export of gas turbines to Crimea
It is being reported today that the Hamburg Public Prosecutor’s Office is currently investigating five individuals in relation to the export from Germany to Crimea of gas turbines manufactured by Siemens.
The broader investigation into the export of these turbines has been ongoing since 2018. See our earlier post.
Four of the individuals being investigated are German nationals, three of whom worked for Siemens in Russia, and the fifth is a Swiss national.
Denmark – sentences and fines for breach of Syrian sanctions
Two Danish companies have been convicted of exporting 177,000 tonnes of jet fuel to Syria in breach of the EU’s sanctions.
In total some 33 transactions took place between 2015 and 2017, with the exports routed through Russian companies bound for Syria.
The company Dan-Bunkering was fined DKK 30 million ($4.6m), with a further DKK 15 million of unlawful profits confiscated.
The parent company Bunker Holding was fined DKK 4 million.
The Dan Bunkering CEO was also convicted and given a four-month custodial sentence , suspended pending a one year probation period.
Denmark – Danish regulator criticizes Danske Bank’s KYC failings
The Danish Financial Services Authority has today published its findings in relation to Danske Bank’s internal compliance function.
The findings included:
The Danish FSA finds that there is a risk that possible breaches of sanctions may not be detected by the bank’s sanctions screening because the bank does not have procedures in place for cooperation, including the exchange of information, between the units responsible for sanctions screening, customer due diligence data and transaction monitoring.
The Danish FSA also finds that there is a risk that possible breaches of sanctions may not be detected and escalated to the bank’s team of experts in the Sanctions & Embargo Team, who investigate possible breaches of sanctions, because the employees of the units of the bank who deal with customer due diligence data and transaction monitoring to prevent breaches of sanctions receive no training.
In addition, the Danish FSA finds that there is an increased risk of employee errors and abuse in the sanctions area because of matters relating to the bank’s internal controls in the sanctions area, including the fact that the four-eyes principle is not applied in connection with the screening of customers, the organisation of controls of manual processes for escalation as well as the organisational embedding of the Sanctions and Embargo Team in Group Compliance.