United Kingdom – OFSI reveals 706 Russian sanctions investigations opened since February 2022

As first brought to wider attention by the Global Sanctions site, the UK’s Economic Secretary has provided a written answer on the UK Parliament’s website to the question: “how many investigations by the Office of Financial Sanctions Implementation into breaches of Russian sanctions (a) are open and (b) have been undertaken since February 2022“.

The answer stated that 388 cases have been investigated by OFSI and closed since February 2022, and that 318 investigations are currently open.

This is a total of 706 investigations opened by OFSI into potential or alleged Russian sanctions breaches in the UK since February 2022.

In that time OFSI has imposed two fines (here and here) in relation to Russian sanctions and disclosed one other breach by Wise Payments Limited (here).

This means that 385 of OFSI’s opened Russian investigations since February 2022 were closed without further action.

As of April 2023, OFSI was reporting it had 172 lives cases ongoing, indicating that there has been a significant increase since then.

United Kingdom – National Crime Agency gives update on sanctions enforcement

As first reported by the BBC, the National Crime Agency has written to the Chair of the Treasury Committee of the House of Commons to respond to a series of questions about the NCAs sanctions enforcement efforts to date.

The letter confirms that there have been no convictions obtained under Russian sanctions, or indeed any sanctions regime since the coming into force of the Sanctions and Anti-Money Laundering Act in January 2021.

The NCA also stated that “a very small proportion” of its workload is sanctions-related, but it would not disclose how many cases had been referred to it by OFSI or any other body, or how many active investigations followed from the 5,600 sanctions-related suspicious activity reports it received in the year 2022-2023.

The letter also stated:

the NCA’s Combatting Kleptocracy Cell (CKC) has delivered over 150 disruptions, which include: asset freezes and forfeiture, taking action against key enablers, and supporting international partners” and then gave a number of specific examples including the successful forfeiture of £780,000 obtained in July 2024.

Another example given was “The arrest of enablers in the regulated sector who support the transactions of corrupt elites“, although no further detail was provided.

Finland – sanctions enforcement statistics: over 900 investigations, hundreds of fines and dozens of convictions

Press reporting in Finland has provided an update on Finland’s sanctions enforcement.

The update provides:

  • over 900 preliminary investigations commenced by Finnish Customs:
    • 13 started between 2018 and 2021;
    • 306 started in 2022;
    • 492 started in 2023; and
    • 83 started in 2024 (January to September, with an uncertain number since then)
  • “More than half” involved minor regulatory offences and have been resolved by monetary fines without recourse to the court system. These cases are further described as: “The fine cases mainly concern private individuals who have exported small quantities of banned goods across the border. Private individuals have exported, for example, luxury goods, not equipment needed by the military“.
  • “Dozens” of convictions and fines imposed by the courts for more serious offences. These are described as: “characterized by planning, systematicity and the pursuit of significant financial gain. Most often, they involve equipment needed on the front line. … The perpetrators in such cases are typically small or medium-sized export or logistics companies“.

The report provides no further details on the precise number of fines, the amount of fines, or other sentencing involved.

A separate report notes that the Finnish Navy has established a controlled area in the Gulf of Finland where Russian-linked vessels are inspected. This de facto maritime detention zone is encircled by Finnish naval forces and that currently 20 Russian “shadow fleet” vessels are “under scrutiny, with several facing potential long-term detention“.

Finland – sanctions investigation closed into returned Russian art

In April 2022 Finnish Customs seized over 200 pieces of art being shipped back to Russian museums such as the State Hermitage Museum and the Tretyakov Gallery.

It is now being reported that at that time an investigation was commenced by Finnish Customs working with the Finnish Foreign Ministry as to whether permitting the onward transit of the objects and artefacts, or the shipments themselves, would amount to breaching EU sanctions.

The artefacts were later allowed to travel on to Russia while the investigation continued.

As of 24 December 2024, it is now being reported (in the linked article above) that the investigation has concluded with no further action to be taken.

Bermuda – trust company fined $600,000 for sanctions and AML compliance failings

On 30 December the Bermuda Monetary Authority announced the imposition of a fine of $600,000 on Meritus Trust Company Limited for a series of AML and sanctions compliance failings.

In terms of sanctions compliance the failing was specified as “An overreliance on manual processes to implement international sanctions policies and procedures and sanctions screening“.

The BMA’s on-site investigation was commenced in June 2022 and the company was then given a deadline of July 2023 to complete the necessary remediation. The BMA was satisfied with the company’s efforts and noted a number of mitigating factors such as a low risk of loss to clients, co-operation, the remediation efforts, and the company’s overall culture of compliance.

This is a rare example of a sanctions enforcement fine being imposed in one of the UK’s overseas territories or crown dependencies. The only other example known (to this blog) are the fines and other punishments imposed in Guernsey in 2015/2016.

Estonia – person detained for alleged breach of designated person’s asset freeze

It is being reported that the Estonian authorities have arrested and detained a 65-year old named only as Tatjana, for allegedly managing and handling funds on behalf of the Foundation for the Support and Protection of the Rights of Russian Compatriots Living Abroad, which is a designated person under the EU’s sanctions.

It is alleged that Tatjana received €50,000 from the Foundation and used the money to fund a person’s defence in an ongoing criminal trial in Estonia.

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.

Latvia – 2-year jail sentence for breaching designated person’s asset freeze

It is being reported that the Kurzeme District Court has sentenced the Latvian citizen Valentins Rozencovs, to 2 years in jail.

The sentence was that sought by the prosecution, although the case is subject to appeal.

Rozencovs was the editor-in-chief of Sputnik Latvija which is the Latvian branch of Sputnik which operates under the umbrella of a Russian state-owned media company Rossiya Segodnya.

The Director General of Rossiya Segodnya is a designated person (Dmitry Kiselyov), and the prosecution was based on the premise that the provision of services by Valentins Rozencovs was making economic resources available to a designated person, and that Sputnik Latvija was “owned or controlled” by Kiselyov.

This is the latest in a series of prosecutions relating to Rossiya Segodnya – see our earlier posts, here and here.

Latvia – update on current sanctions enforcement including 5 convictions in 2024

An article in Latvia’s LTV has provided an update on a number of features of Latvian sanctions enforcement.

Firstly, the Customs Administration stated that they had confirmed 2,623 breaches of sanctions so far this year up from 2,175 in 2023.

It was also stated that to date “€662,498.27 worth of goods have been confiscated in favor of the State in criminal proceedings for breach of sanctions”.

This is a substantially higher figure that those for confiscations identified in our recent post summarising Latvian convictions obtained in 2022 and 2023.

The article also stated that a total of 14 prosecutions had been brought in relation to the making available of economic resources to companies (i.e. the websites Sputnik and Baltnews) owned or controlled by Dmitry Kiselyov.

Two of those prosecutions ended in convictions in 2023 (as per our earlier post above), but the article adds that “This year [i.e. 2024], three more cases have ended in fines and community service”.

Lastly, the article adds that there have been two other convictions obtained during 2024, but that none of the 2024 judgments have yet entered into force.

Although not mentioned in the article, it has been confirmed to me by Paulis Iljenkovs of Latvia’s FIU (who has also consented to me sharing the information), that Latvia currently has 382 ongoing sanctions investigations.

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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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