General – Page 23 – European Sanctions Enforcement

July 1, 2024July 12, 2024 by Mark Handley

Poland – sanctions enforcement statistics including 20 fines to date

As part of the press article (behind a paywall) on the recent fines against Novatek Green Energy and Geleo (see our post here), the Polish authorities have also provided an update on their enforcement activity more broadly.

- - Total administrative proceedings commenced: 48
  - Final decisions to date: 33
  - Declination or waiver of fine or finding of no breach: 13
  - Fines imposed to date: 20
  - Ongoing proceedings: 15
  - Total fines to date: 4.8m zloty (c. $1.2m)

Certainly the figure for total fines does not include the fine against Novatek Green Energy (which was 12 million zloty), but it is also a little unclear whether or not the figure includes the fine against Geleo (which was 4m zloty).

The report also notes that most of the 20 penalties have been imposed in 2024, with only two imposed by the end of 2023 for a combined total of 71,000 zloty (c. $17,700).

These enforcement actions appear to relate to a mix of EU and the separate Polish sanctions.

No information has been provided as to the conduct which gave rise to the fines, or who the fines were imposed on.

May 31, 2024 by Mark Handley

Denmark – investigation closes into alleged import of fuel from partly Russian-owned refinery in India

Further to our earlier post regarding an investigation by the Danish Business Authority into allegations that the Danish shipping company Hafnia, was importing refined fuels from a refinery in India that may have been owned or controlled by Rosneft (which is a designated person under the EU’s sanctions), it is now being reported (here – behind a paywall), that the Danish Business Authority has concluded its investigation having determined that it could not establish that there had been a breach of Russian sanctions.

As yet the Danish Business Authority has not issued a statement on its website.

May 16, 2024May 16, 2024 by Mark Handley

United Kingdom – HMRC corrects/changes description of earlier fine to withdraw reference to Russian sanctions

Back in April we posted about a Compound Penalty imposed by HMRC on a company for breaching the UK’s Russian Sanctions Regulations.

The company was fined £1,058,781.79.

HMRC has today issued a changed Notice to Exporters about this fine. The changed description removes any reference to the UK’s Russian sanctions regulations and replaces it with:

“March 2024 – £1,058,781.79 was paid relating to the unlicensed exports of dual use goods controlled by Retained Regulation 428/2009“.

No explanation for the change is given.

May 15, 2024 by Mark Handley

Cyprus – enforcement update including first two sanctions cases referred for prosecution

It is being reported in Cyprus that two cases have been referred to the Prosecutor’s Office for instituting criminal proceedings. No other information was published on these matters.

In addition, yesterday the Economic Crime Investigation Unit provided updates to the Law Office on the progress with 10 of their ongoing cases, including (as we have previously noted) the investigation into asset transfers allegedly in breach of the EU’s sanctions by Alexei Mordashov.

May 13, 2024December 4, 2024 by Mark Handley

Lithuania – Customs Office fines company €329,944

The Lithuanian Customs Office has announced in a press release the imposition of a fine of € 329,944 imposed upon an unnamed Lithuanian company.

The fine was for purchasing goods from the Russian companies which are designated under the EU’s sanctions.

Lithuanian Customs noted that this was the first enforcement by them of the EU’s sanctions on Russian designated persons.

April 29, 2024April 29, 2024 by Mark Handley

The enforcement of sanctions circumvention in Europe

Sanctions circumvention. It is one of the key topics of the moment.

It is a routine question for people to ask which countries provide a circumvention risk. It is also a common perception that enforcement of sanctions circumvention is lacking.

Based on the material in this blog we have listed out below the more than 40 examples where of recent enforcement of sanctions circumvention on a third-country by third-country basis. Where a particular case involved circumvention via several countries they are listed separately.

Continue reading “The enforcement of sanctions circumvention in Europe”

April 5, 2024 by Mark Handley

Cyprus – sanctions investigation into purported share transfer by Mordashov in the “final stages”

Further to our earlier post there has been an ongoing investigation in Cyprus in relation to the alleged transfer of over $1 billion in shares by Alexey Mordashov in breach of the asset freeze imposed upon him by the European Union.

It is now being reported that the Cypriot investigation has reached its “final stages”.

The report gives no indication of the outcome of the investigation.

The allegations relate to transfers of the shares in the tourism operator Tui.

February 19, 2024 by Mark Handley

Finland – 700 Russian trade sanctions investigations of which 70 are large and complex

In September 2023, the Finnish Customs authorities announced they had 600 ongoing criminal investigations of which 60 were “aggravated”.

As reported in Wirtschaft Woche Sari Knaapi , the Chief Economic Crimes Investigator at Finnish Customs has now given details of the current figures, stating that there are now 700 ongoing investigations, with around 70 that are described as “large, complex cases”.

January 12, 2024December 9, 2024 by Mark Handley

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.

August 16, 2023December 9, 2024 by Mark Handley

Denmark – 45 sanctions investigations opened so far in 2023

It is being reported that so far during 2023 a total of 45 investigations have been opened by the Danish Business Authority in relation to alleged breaches of the EU’s sanctions against Russia.

Of these:

15 cases have been concluded with no further action taken;
2 cases have been referred to the Police;
23 investigations remain open; and
in 5 cases the Danish Business Authority determined that the case did not fall “within the authority’s competence”.

No further details on the cases have been published.