Anti-Terrorism – European Sanctions Enforcement

October 6, 2025October 6, 2025 by Mark Handley

Netherlands – arrest on suspicion of terrorist financing

In an investigation led by the Public Prosecutor’s Office, the Dutch FIOD last week conducted raids on two homes and arrested one individual suspected of transferring bitcoins valued at €5,000 to individuals who had joined terrorist organizations in breach of the Dutch Sanctiewet.

The transfers are said to have taken place between 2019 and 2020.

The FIOD Press release acknowledges the support of Europol in providing technical assistance and facilitating cooperation from other (unnamed) countries.

September 8, 2025September 8, 2025 by Mark Handley

United Kingdom – OFSI issues Disclosure Notice for bank that allowed designated person to use funds

The Office of Financial Sanctions Implementation (“OFSI”) has today issued a Disclosure Notice against Vanquis Bank Limited.

Vanquis failed to react quickly enough to the designation of one of its customers under the UK’s anti-terrorism sanctions permitting a withdrawal (of £200) a day after the designation, and a purchase (of £8.99) five days after designation.

OFSI had written to Vanquis in advance of the designation to warn it that an unnamed customer of the bank was about to the designated. A day after the designation the Bank had flagged the possible match with a customer, but it took 8 days to confirm the match.

Just 5 days after the match was confirmed Vanquis reported the breach to OFSI.

In the overall circumstances, including the low value of the breaches, OFS declined to impose a fine.

It is worth noting that OFSI describes the breaches as VBL itself “made funds available to a designated person”, rather than facilitating or some other categorisation.

August 25, 2025August 25, 2025 by Mark Handley

UK – suspended custodial sentence for refusal by designated person to provide financial information

Further to our earlier post, sentence has been passed in relation to the conviction of Aozma Sultana for refusing the provide financial information to OFSI despite repeated requests. The judge noted that the information had still not been provided.

The judge stated that the starting point for such an offence should be a custodial sentence of 15 weeks. Evidence was presented, however, that Aozma Sultana was the primary care provider for her 38-year-old wheelchair-bound brother, who suffers from cerebral palsy.

On that basis the judge sentenced to Aozma Sultana to 10 weeks’ imprisonment, suspended for 12 months. The court also ordered Sultana to complete 50 hours of unpaid work and 25 days of rehabilitation.

June 30, 2025June 30, 2025 by Mark Handley

United Kingdom – conviction for sanctioned person failing to provide financial information

Global Investigations Review (behind a paywall) has reported on the conviction in the UK of Aozma Sultana.

As previously posted, the UK’s Charity Commission has started an investigation into Aozma Sultana in April 2024. She was designated under the UK’s post-Brexit terrorism sanctions.

She answered “do not remember” to most of the questions sent to her upon her designation, and did answer the requisite questions on three other occasions – twice more when OFSI chased for responses, and again after he arrest.

Sentencing is to take place on 6 August.

February 10, 2025February 10, 2025 by Mark Handley

United Kingdom – designated person charged with failing to disclose their assets

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.