2024 – Page 20 – European Sanctions Enforcement

February 9, 2024March 19, 2024 by Mark Handley

Latvia – further sanctions enforcement statistics including seven convictions

The Latvian authorities have provided a further update to their enforcement efforts. As reported:

- 281 sanctions-related suspicious activity reports in 2022
- 510 sanctions-related suspicious activity reports in 2023
- 310 criminal cases commenced
- 22 prosecutions in which the trial has started
- 7 convictions to date.

Of the convictions, all involved guilty pleas and all involved Latvian nationals. The highest penalty related to the export of a luxury car, and the fine was €170,000.

The conduct prosecuted included in relation to the sale of a professional footballer to a club owned by a company designated under Belarus sanctions, and the provision of content to the Russian Federal News Agency.

UPDATE: It has now (18 March 2024) been reported that the fine imposed in relation to providing economic resources to the Russian news agency in the form of employment services, was €15,500.

February 9, 2024 by Mark Handley

Germany: BaFin investigation into bank ongoing

There has been press reporting into the ongoing investigation by the German financial service regulator, BaFin, into the German bank Varengold Bank AG.

The investigation remains ongoing and so far no individuals have been accused of wrongdoing, and no reference has been made in relation to a criminal prosecution.

For our earlier post regarding the BaFin announcement see here.

February 7, 2024March 15, 2024 by Mark Handley

UK – FCA investigating banks over Iran sanctions allegations

Following widespread press reports (initially in the Financial Times) that a series of front companies linked to the Iranian Revolutionary Guard held accounts in the UK with Lloyds Bank and Santander, it is now being reported (behind a paywall) that both banks have been contacted by the Financial Conduct Authority in relation to the allegations.

Both banks have denied breaching sanctions.

February 2, 2024 by Mark Handley

Moldova – first known investigation into Russian sanctions breach

It has been reported that the Moldovan authorities are investigating allegations that three Moldovan companies have sold $15m in aircraft parts to Russian airlines.

Moldova, although not a part of the EU, has adopted its own sanctions against Russia.

The three companies are Airrock Solutions, Aerostage Services and Maxjet Service. It is alleged the companies acted as intermediaries, purchasing the parts from suppliers and then on-selling.

It is being reported that the companies deny knowing that the parts were being delivered to Russia and that they each thought the parts were going to other CIS countries.

The confirmation of an investigation is reported to have come from the office of the President of Moldova.

February 1, 2024February 1, 2024 by Mark Handley

United Kingdom – NCA charges Russian national with seven counts of circumventing sanctions

It has been reported today that the UK’s National Crime Agency has arrested and charged Dmitry Ovsyannikov, a Russian national, with seven counts of circumventing sanctions as well as two money laundering charges.

Ovsyannikov was formerly the governor of Russian-seized Sevastopol and was designated by the EU in 2017 and then post-Brexit by the UK in 2020.

He is due to first appear in Southwark Crown Court on 20 February. He was arrested on 22 January.

To date the National Crime Agency has not issued a press release

January 25, 2024 by Mark Handley

Latvia – announcement of 258 ongoing criminal prosecutions

In an earlier post we reported that the Latvian authorities had 14 ongoing criminal prosecutions.

This morning, Raimonds Zukuls of the Latvian State Revenue Service has given an interview announcing that 114 criminal cases were opened during 2022 and a further 144 cases were opened during 2023.

These cases all concern the EU’s Russian and Belarusian sanctions. It was also said that most cases relate to electrical goods, car parts, luxury goods, timber products, fuel, fodder and metal products.

It was also stated that over 5,000 imports/exports had been stopped by the State Revenue Service.

January 23, 2024January 25, 2024 by Mark Handley

Netherlands – three arrested on suspicion of circumventing Russian sanctions

The Dutch FIOD has today announced three arrests as part of an ongoing criminal investigation into suspected exports in circumvention of the EU’s trade sanctions against Russia.

The individuals are two men from Diemen and a woman from The Hague. The men were both directors of a company founded in 2017, and the arrested woman was an employee.

UPDATE: it is now being reported that the Dutch company involved is ETW-Tekhnologiya and that the company’s founder, Mikhail Volovik, is being sought but has not yet been arrested

The goods are described as technological and laboratory goods capable of military use – i.e. dual-use goods.

Searches and witness interviews have taken place in the Netherlands, Germany, Latvia, Lithuania and Canada.

January 22, 2024January 22, 2024 by Mark Handley

UK reports Russia to UN North Korean sanctions committee

It has been reported today that the UK has provided the UN Committee responsible for oversight of the UN’s sanctions against North Korea with a dossier of evidence said to establish breaches of those sanctions by Russian shipping.

The Committee has the power to designate vessels which it finds were complicit in breaching the existing sanctions.

January 19, 2024December 9, 2024 by Mark Handley

Denmark – Danish FSA concludes investigation into payment services provider

The Danish FSA has issued a press release stating that an investigation it commenced into Nets Danmark A/S, has not resulted in a need for any further regulatory action to be taken.

The investigation was commenced in May 2023 and related to compliance with EU sanctions in general and Russian and Belarusian sanctions in particular.

January 18, 2024 by Mark Handley

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.