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 – sentences and fines for breach of Syrian sanctions

Two Danish companies have been convicted of exporting 177,000 tonnes of jet fuel to Syria in breach of the EU’s sanctions.

In total some 33 transactions took place between 2015 and 2017, with the exports routed through Russian companies bound for Syria.

The company Dan-Bunkering was fined DKK 30 million ($4.6m), with a further DKK 15 million of unlawful profits confiscated.

The parent company Bunker Holding was fined DKK 4 million.

The Dan Bunkering CEO was also convicted and given a four-month custodial sentence , suspended pending a one year probation period.


Denmark – Danish regulator criticizes Danske Bank’s KYC failings

The Danish Financial Services Authority has today published its findings in relation to Danske Bank’s internal compliance function.

The findings included:

The Danish FSA finds that there is a risk that possible breaches of sanctions may not be detected by the bank’s sanctions screening because the bank does not have procedures in place for cooperation, including the exchange of information, between the units responsible for sanctions screening, customer due diligence data and transaction monitoring.

The Danish FSA also finds that there is a risk that possible breaches of sanctions may not be detected and escalated to the bank’s team of experts in the Sanctions & Embargo Team, who investigate possible breaches of sanctions, because the employees of the units of the bank who deal with customer due diligence data and transaction monitoring to prevent breaches of sanctions receive no training.

In addition, the Danish FSA finds that there is an increased risk of employee errors and abuse in the sanctions area because of matters relating to the bank’s internal controls in the sanctions area, including the fact that the four-eyes principle is not applied in connection with the screening of customers, the organisation of controls of manual processes for escalation as well as the organisational embedding of the Sanctions and Embargo Team in Group Compliance.

Denmark – charges for breach of Syrian sanctions

Denmark’s financial crimes unit on Wednesday announced charges against a Danish company suspected of violating EU sanctions on Syria by delivering large quantities of fuel to Russian warplanes there.

The 33 transactions, involving 172,000 tonnes of kerosene, carried out between 2015 and 2017, amounted to 647 million kroner (87 million euros, $102 million), according to the Danish State Prosecutor.

Danish media has reported the company as Dan-Bunkering. A holding company and the director of one of the companies involved are also being prosecuted.

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The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

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