2019 – Page 3 – European Sanctions Enforcement

April 8, 2019January 11, 2024 by Mark Handley

France – banking regulator finds breaches but does not fine

The Sanctions Commission of the French Banking Regulator (the ACPR) has published its decision from disciplinary proceedings against Raguram International.

Between 2015 and 2017, Raguram had failed to conduct KYC on its customers and failed to incorporate the lists of Eu sanctioned persons into its systems and controls framework.

At the time Raguram had not recognised that its controls environment was defective, but it had subsequently implemented stricter policies and procedures and purchased a compliance solution.

As a result of these steps no fine was imposed.

April 3, 2019March 15, 2024 by Mark Handley

UK – HMRC fines exporter £82,152.33

The UK’s HMRC has today announced that it has fined a UK exporter £82,152.33 for the unlicensed exports of military goods.

The identity of the exporter, and of the destination for the goods, were not published.

April 3, 2019January 11, 2024 by Mark Handley

Germany – company fined €11 million and three managers sentenced for unlicensed exports

Three managers of Sig Sauer, the arms manufacturer have been convicted (after guilty pleas) of the unlicensed export of small arms to Colombia. See our earlier post.

One manager was fined €600,000 and given an 18-month suspended prison sentence. Another was fined given a 10-month suspended sentence and also fined €600,000. A third was fined €60,000 and given a 10-month suspended sentence.

The company itself was fined €11 million.

April 1, 2019February 26, 2024 by Mark Handley

Netherlands – individual convicted for transfers to ISIS family members

The Dutch authorities have obtained the conviction of an individual for making financial transfers to two family members in breach of the EU’s sanctions against ISIS.

Five transfers were made in total with the largest being €3,500.

The man was given a suspended 100 day prison sentence with a 2 year probation period and 240 hours of community service.

March 25, 2019January 11, 2024 by Mark Handley

UN Panel of Experts investigating German firm re North Korean allegations

It has been reported today that the United Nations Panel of Experts on its North Korean sanctions is investigating possible sanctions breaches by the German company Müller + Partner GmbH.

The allegations relate to the shipment of luxury goods to North Korea and involve transshipment through Singapore.

March 8, 2019March 15, 2024 by Mark Handley

UK – OFSI imposes further financial penalty

OFSI has today imposed a £10,000 penalty on Travelex Limited in relation to a £204 transaction involving the funds of a designated person.

This penalty is factually related to the same transaction as was the subject of OFSI’s first penalty.

While the fine itself is very small, that OFSI has imposed a fine in relation to such a small transaction is perhaps itself of significance.

February 21, 2019January 11, 2024 by Mark Handley

Germany – company fined €3.7 million for illegal arms exports

The German arms manufacturer Heckler & Koch has today been fined €3.7 million for illegal arms exports to Mexico.

The conviction relates to the export of over 4,000 assault rifles and other weapons and ammunition. The fine included confiscation of the gross profits from the sales.

Two Heckler & Koch employees were also convicted and given suspended prison sentences of 17 and 22 months respectively.

February 18, 2019January 11, 2024 by Mark Handley

Netherlands – two companies and three individuals convicted of Iran exports

The Dutch District Court in Limburg has convicted two companies and three individuals of unlicensed exports of gas turbine machinery to Iran.

The companies were Euroturbine BV, and its Bahraini subsidiary, and they were fined €500,000 and €350,000 respectively.

The exports were routed via indirect channels to to and mask the destination.

The individuals were respectively sentenced to 12 months in jail, of which 11 months were suspended and 240 hours of community service; 8 months in jail, of which 7 months were suspended and a community service of 200 hours. The third individual , a company employee, was sentenced to 180 hours of community service.

A fourth individual had earlier pled guilty and been sentenced to 120 hours of community service.

February 7, 2019January 11, 2024 by Mark Handley

Belgium – convictions for breaching Syrian sanctions

It was reported today that the Penal Court of Antwerp has convicted three Belgian companies and associated individuals of breaching the EU’s Syrian sanctions by exporting 168 tons of isopropranol which is a dual-use product.

AAE Chemie Trading was conditionally fined €346,443 with €50,000 effective. Anex Customs was fined €500,000 of which €100,000 is effective and Danmar Logistics were fined between €75,000 of which €50,000 is effective

Rolf Rippen, the manager of AAE Chemie Trading was sentenced to four months in jail suspended, while Herman Van Landeghem, a manager of Anex Customs and Danmar Logistics, received a 12-month custodial sentence.

January 25, 2019March 15, 2024 by Mark Handley

UK – HMRC compound penalties for three companies for export control breaches

It has been announced today that the UK’s HM Revenue & Customs has issued compound penalties ranging between £1,000 and £4,000 to 3 separate UK Exporters.

These related to unlicensed exports of dual use goods and export breaches controlled by The Export Control Order 2008.