A fine imposed by Luxembourg’s financial services regulator on the Luxembourg subsidiary of the Allianz Group has become public after a court dismissed an appeal.
The fine of €283,000 was first imposed on 25 March 2022, but only published on 4 April 2025 after the conclusion of the court challenge.
One of the compliance issues identified included failures to “provide evidence of complete initial and ongoing name screening against … sanctions lists”.
On 30 December the Bermuda Monetary Authority announced the imposition of a fine of $600,000 on Meritus Trust Company Limited for a series of AML and sanctions compliance failings.
In terms of sanctions compliance the failing was specified as “An overreliance on manual processes to implement international sanctions policies and procedures and sanctions screening“.
The BMA’s on-site investigation was commenced in June 2022 and the company was then given a deadline of July 2023 to complete the necessary remediation. The BMA was satisfied with the company’s efforts and noted a number of mitigating factors such as a low risk of loss to clients, co-operation, the remediation efforts, and the company’s overall culture of compliance.
This is a rare example of a sanctions enforcement fine being imposed in one of the UK’s overseas territories or crown dependencies. The only other example known (to this blog) are the fines and other punishments imposed in Guernsey in 2015/2016.
The Rotterdam District Court has largely upheld a fine of €95,000 imposed on a trust services provider by the Dutch National Bank.
The DNB’s investigation started in 2019, and the fine was originally imposed on 2022.
The fine related to compliance failings including both money laundering and sanctions failures. The firm’s policies and procedures were insufficient and there was a lack of proper identification of the UBO and of ongoing diligence.
On appeal the fine was reduced to €90,250 due to an argument that the investigation process had been unduly lengthy,
The UK’s Financial Conduct Authority has today fined Starling Bank £28,959,426 for sanctions compliance failings.
The Final Notice states that the bank became aware in January 2023 that its screening was being done against a small sub-set of the Consolidated List of sanctions targets.
The FCA described the compliance program at Starling as “shockingly lax”.
The FCA also noted that the fine would have been £40,959,426 without Starling’s agreement to resolve the matter.
The UK’s Office of Financial Sanctions Implementation has today issued notice of a civil monetary penalty it has imposed on a company called Integral Concierge Services Limited (“ICSL”).
The penalty was for £15,000.
The fine related to 26 payments made to, or received from, a designated person under the UK’s Russian sanctions. The payments related to property management including collecting rent, paying for maintenance, and ICSL taking its own management fees. The designated person was not named.
The company did not initially self-disclose, but did then cooperate including by disclosing breaches that had not yet been identified by OFSI.
The company also breaches the reporting requirements under several general licences, but OFSO chose to not fine in relation to those breaches but rather to treat those failures as aggravating factors.
Germany’s Federal Criminal Police have seized the infrastructure of 47 Russian-language no-KYC cryptocurrency exchanges.
The website announcing the action (called “Operation Final Exchange”) states: “We have found their servers and seized them – development servers, production servers, backup servers. We have their data – and therefore we have your data. Transactions, registration data, IP addresses
Our search for traces begins. See you soon“.
It is being reported that the seizures, while certainly targeting a range of financial crimes, were also driven by the use of these exchanges as a means of circumventing sanctions, particularly by designated Russian banks.
It is likely that this Operation Final Exchange will generate substantive financial intelligence and further enforcement actions.
Luxembourg’s financial services regulator, the CSSF, has today announced a fine of €40,000 on Dock Financial S.A.
The fines relates to AML and sanctions compliance failings identified as part of an on-site inspection between December 2021 and November 2022.
In relation to sanctions, the CSSF has found that:
“A substantial part of the EMI’s client portfolio was not subject to name screening controls on a daily basis, over a substantial period of time, thus constituting a failure to comply with the obligation to detect persons, entities and groups subject to restrictive measures in financial matters without delay so that the necessary restrictive measures can be applied to them in line with all United Nations Security Council resolutions, acts adopted by the European Union (resolutions and acts directly applicable in Luxembourg) and national regulations“.
This was identified as a breach of CSSF regulations requiring detection of designated persons.
Luxembourg’s Financial Intelligence Unit (the CRF) has published its Annual Report which includes statistics on sanctions-related SARS and investigations, as well as an indication of funds frozen as part of these investigations.
The Commission de Surveillance du Secteur Financier (CSSF) in Luxembourg has imposed fines of €109,000 and €17,200 for compliance failings on abrdn Investments Luxembourg S.A.
The fine of €17,200 related to failings in relation to AML/CFT, and included in these failings was failure to “perform initial name screenings controls against international and European financial sanctions lists”.
The CSSF had conducted on-site inspections in 2020.
Lithuania’s Financial Crimes Investigation Service has imposed a fine of €8.23m for breaches of the EU’s sanctions and a fine of €1.06m for breaches of Lithuania’s Law on the Prevention of Money Laundering and Terrorist Financing.
The company fined is UAB Payeer. The press release notes that the company did not cooperate with the investigation and did not provide responses to questions raised.
The investigation commenced after an inspection in 2023 that was conducted after Payeer commenced its operations in Lithuania.
Payeer operated a crypto exchange at Payeer.com which allowed customers to make transfers to or from Russian banks that were designated under EU sanctions.
The AML fine relates to the failure to conduct KYC and the failure to report suspicious transactions.
The press release notes that Payeer had revenues of more than €164m during the 1.5 years of its breaches, but does not note what proportion of this came from prohibited activity.
