Netherlands – sanctions fines imposed by Dutch National Bank upheld and reduced on appeal

An unnamed financial services provider regulated by the Dutch National Bank has challenged fines imposed upon it in relation to KYC and due diligence failings including in relation to sanctions screening.

The DNB had initially fined the provider €1.1m and €625,000, but these were reduced through a review process to €850,000 and €480,940.

The first fine in particular related to allegations of a failure to screen any of the sample of analysed customers against EU and Dutch sanctions lists.

On further appeal to the Rotterdam District Court the fines were upheld but further reduced to €718,841.25 and €451,250.

Latvia – importer referred to criminal authorities

It has been reported today that the Latvian National Regional Development Agency (the “VRAA”) has referred the Latvian company LLC Lanekss to the criminal authorities for investigation.

The allegations arise out of LLC Lanekss being a seller of products on Latvia’s electronic public procurement sale platform – the EIS.

The Latvian state broadcaster (LTV) purchased tea through the EIS which when delivered was stated to have been manufactured in Russia.

As article 5k of EU regulation 833/2014 prohibits the award of a contract within the scope of the EU’s Public Procurement legislation to a Russian company or individual, or a company more than 50% owned by a Russian company or individual,  the VRAA has referred the case to law enforcement for investigation.

Finland – five charged with EU Russian sanctions offences

It has been reported that the Finnish authorities have charged five individuals with sanctions offences.

The allegations relate to the export of drones to Russian in breach of EU sanctions.

The first defendant is Gabriel Temini who is the CEO of the Finnish companies Luminor and Siberica.

Three employees of Siberica have also been charged as well as an employee of a freight forwarding company.

The charges are denied.

Trial is scheduled to commence on 26 January 2024.

Denmark – three charged in relation to alleged arms exports to Russia

It is being reported that the NSK – Denmark’s National Unit for Serious Crime is investigating allegations that a Danish arms manufacturer has been exporting arms to Russia in breach of the EU’s sanctions.

The company, and the company’s CFO and CEO are all reported to have been charged on suspicion of exports to a Russian arms manufacturer.

The company successfully applied to the court for a ban on being named in the press.

The allegations include the setting up of a bespoke corporate structure to conduct the exports via third countries.

The enforcement of sanctions across Europe – 2017 to the present: a new resource

We are today launching a new blog dedicated and focused on the regulatory and criminal enforcement of financial and trade sanctions across Europe – the EU, as well as countries such as Switzerland, the United Kingdom and Norway.

The entries on the page can be filtered by enforcing country, the year of enforcement, business sector, or the applicable sanctions regime. The posts are also fully text searchable.

The blog documents hundreds of enforcement actions in the period from 2017 to the present day in a total of 22 different European jurisdictions, as well as the existence of over 1,300 announced criminal or regulatory investigations which are current and ongoing across the continent.

These pages will serve as a repository for up-to-date enforcement statistics, including the cumulative of fines and penalties and the number of successfully-concluded enforcement actions.

Continue reading “The enforcement of sanctions across Europe – 2017 to the present: a new resource”

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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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