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.


European Sanctions Enforcement – milestone of over 2000 announced and active investigations reached

With the recent news that Finland has increased the number of its ongoing investigations, Europe (meaning the EU, the UK, Switzerland, etc) has reached the milestone of over 2,000 ongoing and public sanctions enforcement investigations being undertaken by regulators and prosecutors.

No doubt there are other investigations which are ongoing in the countries shown on the graph, and no doubt there are investigations ongoing in countries not shown and which remain confidential.

How many of these will be dropped due to inconclusive evidence or exculpatory evidence, and how many will lead to a conviction or fine or acquittal is impossible to say.

It is, without question, an unprecedented level of enforcement.


Cyprus – company raided as part of sanctions investigation

Last week the compliance and oversight department of the Cyprus Bar Association raided the premises of the company Finsol controlled by a Greek national regulated by the CBA.

The raid is part of a wider investigation which includes the Cypriot Anti-Money Laundering Authority and Cyprus police.

While the investigation includes allegations unrelated to sanctions, part of the investigation, further to our earlier post, includes allegation of back-dated asset transfers in relation to the company Santinomo Limited, allegedly in an attempt to avoid the impact of a new designation.

Cyprus – more than 40 ongoing Russian sanctions investigations and first indictments expected soon

The Cypriot authorities have more than 40 ongoing criminal investigations related to alleged breaches of the EU’s Russian sanctions.

It is being reported that yesterday the current status of “all open cases exceeding 40 were reviewed” by the Law Office and the state’s Attorney General, with the Office for Economic Crime Investigation.

It is also being reported that for the completed investigations “indictments will be prepared to initiate criminal prosecutions in court”.

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.

Cyprus – investigation into potential attempted sanctions circumvention

It has been reported today that the Company Registrar in Cyprus, alongside the Cyprus Bar Association, are investigating an instance of possible Russian sanctions breaches.

The investigation relates to allegations that two days after additions to the OFAC SDN list a Cypriot company newly-filed documents purporting to show corporate rearrangements dating back several years which is accurate and reliable would remove the company from the impact of the US listing.

It is unclear whether the investigation relates to any breaches of the EU’s sanctions.


Cyprus – 28 reports of possible sanctions breaches in last 6 months

It has been reported today that 28 reports to the Cypriot authorities have been received between May and November of this year.

The reports are said to have come from multiple sources including the Ministry of Finance, the Foreign Ministry, the anti-money laundering unit MOKAS, the Association of Cyprus Auditors, the Cyprus Bar Association, the Legal Service, and the Central Bank.

© 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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