Financial Services – Page 3 – European Sanctions Enforcement

October 20, 2025October 20, 2025 by Mark Handley

Germany – hearing begins for confiscation of €720m from sanctioned Russian bank

Further to our earlier post, it is being reported that the confiscation proceedings are now ongoing in the Frankfurt Higher Regional Court seeking to confiscate €720 million as the proceeds of crime from a sanctioned Russian bank.

According to reports the Russian bank sought to transfer these funds out of Germany in the immediate wake of being designated by the EU in June 2022, but the banks asked to process the payments refused to proceed.

As funds transferred in breach of the asset freeze imposed on the bank, these funds have been characterized by the prosecution as the proceeds of crime and so subject to confiscation under applicable anti-money laundering laws.

The case is being heard before a five judge bench.

October 6, 2025 by Mark Handley

Latvia – State Security Service seeks prosecution for providing project management services

Latvia’s State Security Service (the VDD) is seeking the prosecution of two Latvian nationals accused of providing project management services to Russian companies.

This is one of few known prosecutions for breaching the EU’s professional services prohibitions. It is alleged that the individuals were co-owners of a company through which the services were provided.

The investigation started in January of this year.

September 8, 2025September 8, 2025 by Mark Handley

United Kingdom – OFSI issues Disclosure Notice for bank that allowed designated person to use funds

The Office of Financial Sanctions Implementation (“OFSI”) has today issued a Disclosure Notice against Vanquis Bank Limited.

Vanquis failed to react quickly enough to the designation of one of its customers under the UK’s anti-terrorism sanctions permitting a withdrawal (of £200) a day after the designation, and a purchase (of £8.99) five days after designation.

OFSI had written to Vanquis in advance of the designation to warn it that an unnamed customer of the bank was about to the designated. A day after the designation the Bank had flagged the possible match with a customer, but it took 8 days to confirm the match.

Just 5 days after the match was confirmed Vanquis reported the breach to OFSI.

In the overall circumstances, including the low value of the breaches, OFS declined to impose a fine.

It is worth noting that OFSI describes the breaches as VBL itself “made funds available to a designated person”, rather than facilitating or some other categorisation.

September 8, 2025September 8, 2025 by Mark Handley

Netherlands – fine for failure to provide regulator with sanctions compliance information reduced on appeal

The Rotterdam District Court has issued a judgment reducing a fine of €500,000 imposed by the AFM (Autoriteit Financiele Markten) on Tradition Securities and Futures S.A. to €100,000.

The AFM had issued questionnaires in 2020, 2021, and 2022 in relation to TSAF’s compliance with Dutch AML and sanctions laws. The questionnaires were not completed.

In June 2023 the AFM notified TSAF of the intention to impose a fine of €500,000 for the failings. This was imposed in October 2023, and the judgment is the result of an appeal against both any fine and the amount of the fine.

The appeal against the fine itself was dismissed.

In relation to the size of the fine the Court ruled that the AFM failed to take note of a range of factors in its own fines guidance, namely that there was no damage to third parties, no unlawfully obtained gain, no (major) social impact, no significant scale, and no market disruption. Further it was noted that this request for information was a generic annual questionnaire and not in the context of a particular investigation or alleged breaches of sanctions. The Court was of the view that TSAF should have benefitted from a 50% reduction upon the proper application of the fining guidance but then further reduced the fine from €250,000 on the basis that such a fine was “disproportionate “not in reasonable proportion to the nature and seriousness of the violation”.

September 3, 2025September 3, 2025 by Mark Handley

Luxembourg – CSSF fines Alipay €214,000 including for sanctions compliance failings

Luxembourg’s financial services regulator, the CSSF, has issued a fine of €214,000 against Alipay (Europe) Limited SA for various AML and other compliance failings.

Amongst these was a failure promptly deal with “financial sanctions related alerts”, with the CSSF noting that Alipay “would not have been in a position to apply restrictive measures in financial matters without delay”.

August 13, 2025August 13, 2025 by Mark Handley

Iceland – bank fined for sanctions compliance failings

This post is catching up on a previously-missed fine issued on 9 May 2025, and first brought to wider attention by Global Investigations Review.

The Financial Supervisory Authority of Iceland’s Central Bank has fined Fossa fjárfestingarbanka hf for compliance failings including sanctions compliance failings as well as anti-money laundering.

The press release is here, and the more detailed note of the findings and fine is here.

In relation to sanctions the failings were a lack of adequate screening, and a lack of ongoing screening with most files sampled having been screened at onboarding but not subsequently. It is not alleged that these failings permitted breaches of sanctions to take place.

The bank was fined ISK 22,000,000 (approximately €153,000).

Iceland largely adopts the EU’s various sanctions regimes. This is the first example of enforcement in Iceland included in this blog.

August 4, 2025August 4, 2025 by Mark Handley

Guernsey – licence revoked and fines imposed on financial services firm and individual

The Guernsey Financial Services Commission has issued a release regarding the imposition of several fines and the revocation of regulatory authorisations for a firm and an individual.

The firm ITI Trade Ltd was fined £175,000, and Mr Alexi Filatov was personally fined £35,000.

An order has been issued preventing Mr Filatov from holding a regulated position for 2 years and 10 months.

ITI Trade Ltd agreed to surrender its licence.

The compliance failings were first identified by the Commission in 2019, and the firm undertook (or purported to undertake) various remediation programmes (the results of which were doctored for the purpose of submissions to the Commission), before the Royal Court appointed Administration Managers over the firm in July 2022.

The failings relate to a lack of sanctions and AML compliance, due diligence and screening with the Guernsey entity “used to appear to provide investment services from Guernsey, when in reality much of the business was conducted in Russia”.

August 4, 2025August 4, 2025 by Mark Handley

United Kingdom – OFSI imposes a fine of £300,000 for breach of EU Russian sanctions

OFSI has published a Penalty Notice fining a UK company Markom Management Limited (“MML”) £300,000 for breaches of The Ukraine (European Union Financial Sanctions) (No.2) Regulations 2014.

The fine was for issuing a payment instruction to return an overpayment of £416,590.92 to a Russian bank account belonging to a designated person.

The fine was initially set at £400,000, but was reduced through the ministerial review process.

This penalty is noteworthy for a number of reasons:

This enforcement action dates from events in 2018. While underscoring the slowness of OFSI’s enforcement steps it also reinforces the lack of a limitation period for the UK’s sanctions, and the fact that the UK continues to enforce the EU sanctions that were in place before Brexit.
The self-reporting by MML was considered insufficient to trigger a discount to the imposed penalty.
The conduct that warranted the penalty was a person in the UK sending a payment instruction to a bank in Russia to transfer funds to another bank in Russia. This is a reminder of the broad reach of the UK’s criminal jurisdiction when it comes to communications sent in or out of the jurisdiction. This penalty notice sits uneasily alongside the recent civil decision in Celestial Aviation Trading Ireland Ltd & Ors v Volga-Dnper Logistics BV [2025] EWHC 1156 (Comm).

July 1, 2025January 14, 2026 by Mark Handley

France – financial services regulator fines bank €600,000 for sanctions compliance failings

France’s ACPR has issued a press release making public a fine of €600,000 imposed on Banque Delubac.

The detailed Décision, make clear that the compliance failings predominantly relate to AML and CTF failings, but Complaint 9 relates to sanctions compliance. The ACPR noted a failure by the bank to collect data on directors and beneficial owners for more than a quarter of its business customers. Further, the bank applied no screening at all on transactions valued at below €1,000 between 2020 and 2022/2023.

The size of the fine is said to reflect the €3m spent on improving the bank’s compliance, and the bank’s loss for the financial year 2024.

June 11, 2025June 11, 2025 by Mark Handley

Netherlands – DNB issues instruction to trust office regarding sanctions compliance

The Nederlandsche Bank (DNB) has issued a press release relating to Erez Corporate Service B.V.

Erez was issued an “instruction” in June 2021 by the DNB in relation to the remediation of various compliance failings, including compliance with EU sanctions.

Erez has sought to challenge, and then appeal, this instruction, but those efforts have not been successful which is why the DNB are now publishing the details of the instruction.