European Sanctions Enforcement

June 27, 2017January 10, 2024 by Mark Handley

Latvia – three banks fined by regulator for sanctions and AML failings

On June 27, 2017, the Latvian Financial and Capital Market Commission entered into administrative agreements with three different Latvian Banks for failings related to breaches of North Korean sanctions. Each of the banks cooperated with the investigations.

JSC Baltikums Bank and JSC PrivatBank were each fined €35,575 for “weaknesses in customer due diligence and transaction monitoring that led to the situation that bank had been used to circumvent international sanctions requirements imposed against North Korea”.

JSC Reģionālā investiciju Banka, was fined €570,364, for the same failings, but also for “failure to ensure effective functioning of internal control system”. To remedy this, the bank was undertaken to invest €2.8 million on “the improvement of its internal control system in 2017/2018”.

In addition official warnings were issued to those at the bank responsible for AML and CTF controls. The bank also undertook to “assess its AML/CTF internal control system and take the necessary measures to improve its functioning and effectiveness in line with the action plan, to perform external testing on the categorization of customer base and IT solutions, as well as assess the risks associated with cross-border enforcement of sanctions”.

June 13, 2017January 10, 2024 by Mark Handley

France – investigation commenced into allegations of terrorist financing

It was reported today that the French authorities have commenced an investigation into the cement company Lafarge-Holcim with regards to payments made relating to its Syrian manufacturing operations that are alleged to be payments made to designated persons under the EU’s terrorist financing and ISIS sanctions.

May 10, 2017January 10, 2024 by Mark Handley

Netherlands – investigation into trust office ongoing

It is being reported in the Netherlands that the Dutch authorities are undertaking an investigation into trust companies within the BK Group for alleged breaches of the EU’s misappropriation sanctions in relation to the Ukraine.

May 3, 2017January 10, 2024 by Mark Handley

Italy – two year sentence for arms exports to Libya and Iran

As part of the ongoing prosecution of three Italian nationals for arms exports to Libya and Iran in breach of EU sanctions, it has been reported today that one of the defendants, Andrea Pardi, has pled guilty in return for a two-year custodial sentence.

The trial of the remaining defendants is due to start in June 2017.

April 24, 2017January 10, 2024 by Mark Handley

Netherlands – airline fined €40,000 for export of military goods

The District Court of Noord-Holland has today fined a fine of €40,000 on the Dutch airline KLM for its role in the unlicensed export of goods on the EU’s military list from the South African to Ecuador via the Netherlands.

The judgment noted that subsequent investigation had revealed 74 shipments where the required reporting had not been complied with.

April 24, 2017January 10, 2024 by Mark Handley

Netherlands – €50,000 fine for unlicensed exports to Saudi Arabia

A District Court in the Netherlands has imposed a €50,000 fine on logistics provider for its part in the unlicensed export of military goods to Saudi Arabia.

No export licence had been applied for. The value of the contracts is stated to have been US$14 million.

April 21, 2017January 10, 2024 by Mark Handley

Netherlands – 19 year jail term imposed on appeal

The Court of Appeal in Hertogenbosch has upheld and extended the conviction and sentence imposed on an individual for breaches of the EU’s Liberian sanctions.

Amongst other offences, the defendant had supplied arms and munitions to the government of Charles Taylor in breach of sanctions.

At first instance he had been acquitted of some charges and sentenced to 8 years in jail. Both the defendant and the public prosecutor appealed.

On appeal all charges were found proven and a sentence of 19 years was imposed.

April 14, 2017January 10, 2024 by Mark Handley

Netherlands – Dutch National Bank’s fine of trust office upheld on appeal

The District Court of Rotterdam has dismissed an appeal by a trust office against a penalty imposed by the Dutch National Bank.

The penalty was imposed for KYC failings by the trust office specifically in the context of sanctions screening and compliance, including insufficient investigation of the origin of the assets within certain trusts.

The size of the fine is not mentioned in the appeal judgment.

April 13, 2017January 10, 2024 by Mark Handley

Italy – confiscation of illegally-imported Crimean wines

The Italian Financial Police have confiscated wines imported into Italy from Crimea in breach of the EU’s sanctions.

The confiscation took place at the wine fair, Vinitaly, and the wines from Crimea were part of the Russian exhibits. Agricultural products from Crimea are prohibited from import into the EU under the EU’s sanctions.

March 14, 2017January 11, 2024 by Mark Handley

Netherlands – two-year sentence for breach of Al Qaida sanctions

The Court of Appeal in the Hague has upheld the conviction of a man for breaches of the EU’s Al-Qaida/ISIS and Terrorism sanctions.

The individual had transferred €17,000 to his brother who was fighting for ISIS in Syria.

The man was sentenced to 10 months in jail with a further 14 months suspended subject to a three-year probation period.