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.

 

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”

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.

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”.

 

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.

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.

Denmark – two further sanctions investigations referred to the police

It is being reported that the Danish Business Authority has referred two cases to the police for potential further action.

This is further to our earlier post relating to the commencement of the investigations.

Both cases relate to the continuation of operations by designated Russian organisations in Denmark.

These two police investigations add the the 12 already known to have been commenced (see our earlier post).

Denmark – Danish Business Authority investigating possible breaches by two Russian designated persons

It is being reported that the Danish Business Authority is investigating whether the so-called “Russia House” in Copenhagen, which is a designated person under the EU’s sanctions has been breaching the asset freeze imposed upon it.

This follows an earlier report that the Danish Business Authority was also investigating possible breaches by Rossotrudnichestvo.

© 2009- Duane Morris LLP. Duane Morris is a registered service mark of Duane Morris LLP.

The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

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