Updated enforcement statistics are being reported (here behind a paywall, and here in summary) for the Dutch Fiscal Intelligence and Investigation Service (FIOD) and from Dutch Customs.
FIOD is reported to have conducted 30 cases in the three years since February 2022, with six resulting in convictions, and twenty investigations ongoing.
Customs are reported to have started 80 cases, with 16 ongoing, and 64 settled with fines of between €500 and €200,000.
In 2024, probably for the first time ever, Europe (meaning the EU, UK, Switzerland and Norway), imposed and obtained a greater number of fines and convictions; a higher total value of fines; and also a higher single largest fine, for sanctions breaches than those imposed by the authorities in the United States.
The US figures combine the enforcement actions taken by OFAC and BIS, as well as criminal convictions secured by the DOJ.
The European figures are taken from this blog.
The US obtained 52 successfully-concluded enforcement actions, while Europe secured 118.
The US (OFAC and BIS combined) imposed fines equivalent to €56.8m, while Europe imposed a total of €88.5m.
The single largest US fine was $20m in relation to Iran sanctions. The largest fine in Europe was the UK’s £29m imposed on Starling Bank.
On 31 January the Rotterdam District Court published its decision convicting an individual of breaches of the EU’s ISIS sanctions.
The individual was sentenced to 90 days in jail, of which 74 days is suspended for 2 years. Community Service of 80 hours was also imposed.
The transfers giving rise to the offences were US$4,350 and 150,000 Syrian pounds.
The individual was also charged with financing of terrorism and human trafficking.
Ireland’s Gardaí (National Police) have confirmed to Global Investigations Review that it has referred two investigations for prosecution for alleged breaches of the EU’s sanctions imposed on Russian in the wake of the full-scale invasion of Ukraine in 2022.
It was also confirmed that the Public Prosecution Service declined to being charges in both investigations.
One such referral to the DPP was reported to have taken place in April 2023.
In March 2024 it was reported that the Gardaí had four investigations ongoing into suspected Russian sanctions breaches, but the status of those further investigations is unknown.
The District Court in Amsterdam has issued a judgment arising from the export of machinery from the Netherlands to Crimea in 2016 and 2017 for use in the construction of the Kerch Bridge.
The company (a B.V. unnamed in the judgment) reached a settlement with the prosecution, whereby no defence was advanced, no appeal would be lodged, and the company agreed to pay the fine of €120,000.
The court found that the prosecution case was made out, and confirmed the terms of the settlement and the proposed fine.
The judgment does not mention any confiscation of the proceeds of crime.
Judgments have also been released in relation to the related prosecutions of two individuals (here and here), both of whom were acquitted.
The Dutch FIOD has issued a press release relating to the arrest of an individual suspected of various offences including unlicensed ‘hawala’ banking and breaches of the Dutch Sanctions Law.
As part of the investigation a residential property was raised and mobile phones and other devices seized.
It is alleged that the suspect was at the centre of a network capable of large-scale financial transfers from the Netherlands to other countries.
The Dutch FIOD has issued a press release stating that a 57-year old man has been arrested and that the individual and a company are suspected of exporting US$24 million in computer motherboards and graphics cards to Russian customers in breach of the EU’s sanctions against Russia.
Residential and commercial premises were raided, and bank accounts seized.
The exports are alleged to have been done through Hong Kong, the United Arab Emirates and Cyprus
The Spanish authorities have issued a press release confirming a series of raids in the provinces of Barcelona and Valencia and the arrest of five people.
The raids and arrests are said to be the second phase of Operation Probirka, the first phase of which was conducted in October 2024 (see our previous post).
The bodies involved were the National Police and the Tax Agency.
The allegations include the use of front companies and dummy intermediaries in Kyrgyzstan and Armenia, and the export of chemicals which can be used in the manufacture of explosives and chemical weapons.
Further to our earlier post regarding the UK’s Charity Commission investigating Aozma Sultana in relation to possible sanctions breaches, it has now been reported (first by GIR – behind a paywall), that Aozma Sultana has been charged with sanctions offences in the UK and that she appeared in court last week.
Ms Sultana is a designated person under the UK’s anti-terrorism sanctions.
The alleged offence is one of refusing or failing to comply with a request from HM Treasury for information as to her assets and finances.
Trial is currently set for June 2025.
It is being reported that investigations have been commenced in Germany in relation to suspected sanctions breaches by Roman Abramovich.
Actions by the Federal Criminal Police Office and the Central Sanctions Enforcement Office have included raids on properties and the confiscation of luxury cars and artwork.
The suspected breaches of Regulation 269/2014 are the failure to properly or adequately disclose his frozen assets, including a 19th-century villa in Garmisch-Partenkirchen
It is also being reported that Mr Abramovich’s lawyer has said that he is not the ultimate owner of the villa or the confiscated luxury cars.
