As part of the ongoing reporting of an investigation into the sale of a tugboat from Finland to Russia in breach of EU sanctions, it was reported today that the Finnish authorities are have been undertaking over 600 investigations into potential sanctions breaches since February 2022.
Sixty of these are said to be “aggravated” indicating that they are of a more serious, or high value, nature.
The Dutch have announced that the Public Prosecution Service is currently undertaking 55 criminal investigations into suspected breaches of Russian and Belarusian sanctions.
Little information on the breaches is available, but the authorities have stated that roughly two thirds relate to breaches of trade sanctions, and one third to financial sanctions.
As of December the number was at 27, meaning 28 have been added during 2023 to date.
It has been reported today that the German authorities have confirmed the commencement of an investigation following press reporting regarding whether German companies which attended a trade fair in Iran had done so in breach of EU sanctions.
It has been reported in a country-specific report on Sweden by the Royal United Services Institute that the Swedish customs authorities charged and prosecuted a company for Russian trade sanctions offences, but were unable to secure a conviction.
No further details were provided.
The Latvian State Security Service (VDD) has announced that it has forwarded a case to the Prosecution Service for the initiation of criminal proceedings relating to the export of luxury goods to Russian in breach of EU sanctions.
The luxury good in question was a car.
In another announcement today, the VDD has announced the referral of another case for prosecution relating to the import of iron and steel products from Belarus in breach of EU sanctions.
The Dutch Fiscal Information and Investigation Service has announced the arrest of an employee of the Ministry of Defence on suspicion of exporting aircraft spare parts through various companies and countries to Russian in breach of the EU’s sanctions.
The announcement confirms that this is the second arrest in the same investigation with an earlier arrest and raid conducted on 29 August 2023.
It was reported today by Reuters that there are 150 ongoing sanctions investigations being undertaken in Germany.
No further details were published.
In response to questions about Russian sanctions enforcement the Latvian authorities have confirmed that they have 14 ongoing criminal prosecutions of which three relate to exports, including circumvention of sanctions by routing exports through China and central Asia, and the others to breaches of financial sanctions.
The Latvian authorities also stated they received 281 suspicious activity reports during 2022 in relation to Russian sanctions, and had received 309 so far in 2023.
The UK’s financial services regulator has today published a report based on its review of sanctions compliance by a sample of 90 regulated firms.
The FCA emphasised the importance it places on compliance with sanctions and the proactive approach it intends to take to enforcement.
The FCA also published examples of what it considers to be good practice and bad practice. The examples of bad practice include:
(i) insufficient information given to management on sanctions risks, and insufficient management attention;
(ii) global sanctions policies that are insufficiently attuned to the specifics of the UK’s regime;
(iii) over-reliance on third-party screening tools without sufficient oversight or attention to the detail and calibration of such tools;
(iv) insufficient contingency planning in advance of anticipated changes to sanctions;
(v) insufficient resources applied to sanctions compliance resulting in significant backlogs; and
(vi) insufficient and inappropriate calibration of of screening tools allowing either too many false positives, or gaps in screening hits.
It was reported today that the Finnish Central Criminal Police are investigating a Finnish company for exports to Russia in breach of the EU’s sanctions.
The investigation was commenced in 2019, with the offences alleged to have taken place between 2016 and 2020.
The exports were of technology destined for use by arms manufacturers in Russia. It is also alleged that the Finnish company was controlled, albeit not owned, by a designated person under the EU’s Russian sanctions.
