Denmark – sanctions enforcement activity 2022-2024

Presenting a webinar this morning made me aware that this blog had missed a number of stories relating to Danish sanctions enforcement.

I have endeavoured to rectify that gap with a number of posts filling gaps from 2022 through to early 2024. Because I have back-dated the posts so that they appear in the correct sequence it made sense to collect them into a properly new post to  highlight the additions.

Importantly, between February 2022 and August 2023 a total of 98 investigations were opened, with 16 referred to the police. In addition the police have charged a company and two individuals in relation to one particular case.

Denmark – investigation closes into alleged import of fuel from partly Russian-owned refinery in India

Further to our earlier post regarding an investigation by the Danish Business Authority into allegations that the Danish shipping company Hafnia, was importing refined fuels from a refinery in India that may have been owned or controlled by Rosneft (which is a designated person under the EU’s sanctions), it is now being reported (here – behind a paywall), that the Danish Business Authority has concluded its investigation having determined that it could not establish that there had been a breach of Russian sanctions.

As yet the Danish Business Authority has not issued a statement on its website.

Denmark – investigation into importation of aviation fuel from India in potential breach of Russian sanctions

It has been reported that the Danish Business Authority is currently investigating the Danish shipping company Hafnia for possible breaches of the EU’s Russian sanctions.

The allegations relate to the importation in October of 30 million litres of aviation fuel from a refinery in India which may be owned or controlled by designated persons.

Hafnia is reported to have denied the allegations and stated that it acts in full compliance with all relevant laws and regulations.

Denmark – three charged in relation to alleged arms exports to Russia

It is being reported that the NSK – Denmark’s National Unit for Serious Crime is investigating allegations that a Danish arms manufacturer has been exporting arms to Russia in breach of the EU’s sanctions.

The company, and the company’s CFO and CEO are all reported to have been charged on suspicion of exports to a Russian arms manufacturer.

The company successfully applied to the court for a ban on being named in the press.

The allegations include the setting up of a bespoke corporate structure to conduct the exports via third countries.

Denmark – 45 sanctions investigations opened so far in 2023

It is being reported that so far during 2023 a total of 45 investigations have been opened by the Danish Business Authority in relation to alleged breaches of the EU’s sanctions against Russia.

Of these:

  • 15 cases have been concluded with no further action taken;
  • 2 cases have been referred to the Police;
  • 23 investigations remain open; and
  • in 5 cases the Danish Business Authority determined that the case did not fall “within the authority’s competence”.

No further details on the cases have been published.

Denmark – two further sanctions investigations referred to the police

It is being reported that the Danish Business Authority has referred two cases to the police for potential further action.

This is further to our earlier post relating to the commencement of the investigations.

Both cases relate to the continuation of operations by designated Russian organisations in Denmark.

These two police investigations add the the 12 already known to have been commenced (see our earlier post).

Denmark – Danish Business Authority investigating possible breaches by two Russian designated persons

It is being reported that the Danish Business Authority is investigating whether the so-called “Russia House” in Copenhagen, which is a designated person under the EU’s sanctions has been breaching the asset freeze imposed upon it.

This follows an earlier report that the Danish Business Authority was also investigating possible breaches by Rossotrudnichestvo.

© 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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