United Kingdom – former designated person charged with breaching his asset freeze under Russian sanctions

The UK’s National Crime Agency has published a press release confirming that it has charged John Michael Ormerod with two counts of breaches the UK’s Russian sanctions as well as a money laundering offence.

Ormerod was designated by the UK on 20 May 2025, and the charges relate to his efforts to transfer £200,000 on the same day in breach of the asset freeze imposed upon him.

Ormerod’s UK listing had been lifted on 2 March 2026.

France – cement maker Lafarge and eight executives convicted of sanctions and terrorist financing breaches

Further to our earlier posts, a court in Paris had today handed down judgment in the long-running Lafarge prosecution.

The company has been convicted of breaches of the EU’s Syrian sanctions as well as terrorist financing and has been fined €1.125m as well as a separate fine of €4.57m for breach of sanctions.

Of the executives also being prosecuted:

– Bruno Pescheux (former director of the Syrian cement factory) received a 5-year jail term and was fined €225,000;

– Bruno Lafont (former Lafarge CEO) was sentenced to 6 years in jail and fined €225,000;

– Christian Herrault (former deputy Managing Director) was sentenced to five years in jail and fined €225,000;

– Frederic Jolibois (successor to Pescheux) was sentenced to three years in jail, two of which were suspended, and fined €80,000;

– Jacob Waerness was sentenced to 18 months in jail and fined €20,000 and a ban from entering France;

– Ahmad Al Jaloudi was sentenced to 2 years in jail and fined €20,000 and a ban from entering France;

– Amro Taleb, a Syrian intermediary, was sentenced to 3 years in jail and fined and fined €60,000 and a ban from entering France;

– Firas Tlass, tried in absentia, was convicted and sentenced to seven years in jail with a €225,000 fine and a ban from entering France.

It appears that a decision on the confiscation of the proceeds of crime in this case is awaited. The prosecution was seeking confiscation of €30m.

Some of the individual defendants have already indicated their intention to appeal.

Bulgaria – extradition to face US sanctions charges

Further to our earlier post, it is now being reported that the Bulgarian authorities have extradited Russian national Oleg Olshansky to face charges of breaching the US’s Russian sanctions and money laundering.

Mr Olshansky had appealed an earlier decision approving his extradition.

Mr Olshansky and another Russian national extradited from Bulgaria, Mr Sergey Ivin have now been charged by the US authorities.

United Kingdom – Irish subsidiary of Apple fined £390,000 by OFSI

The UK’s Office of Financial Sanctions Implementation has issued a Penalty Notice fining the Irish-incorporated company Apple Distribution International Limited (“ADIL”), £390,000 for breaches of the UK’s Russian sanctions.

ADIL was fined for issuing payment instructions to a UK bank, and for failing to cancel those payment instructions. The two payments in June and July 2022 for a total of £635,618.75 were to Okko LLC, a company wholly owned by the designated person JSC New Opportunities.

OFSI took the view that the instructions issued to a UK bank, and the failure to cancel those instructions, amounted to conduct within the UK for the purposes of the jurisdictional reach of the UK’s sanctions. This is in line with older case law that had established that sending instructions into the UK could amount to an offence within the UK.

ADIL self-disclosed the conduct in October 2022. The Penalty Notice was also arrived at by way of an agreed settlement pursuant to OFSI’s new enforcement procedures.

The penalty is also noteworthy because JSC New Opportunities was designated by the UK at 11am on 29 June 2022. The first payment instruction had been made on 6 June but with a value date of 30 June. The second payment instruction was issued on 30 June with a value date of 28 July 2022.

OFSI took the view that there was a “narrow window” in which the first payment could have been stopped, and that it was an aggravating factor justifying enforcement action that a second payment had been ordered. The Penalty Notice also expressly states that OFSI was relying on the “strict liability” enforcement rules that come into effect in 15 June 2022. Earlier payments made to Okko LLC, while it had been owned by a different designated person were also made in breach of the UK’s sanctions, but were not the subject of OFSI’s enforcement action as they took place before the coming into force of the “strict liability” rules.

OFSI also stated that despite the failings of the external screening provider used by ADLI, it was ultimately ADLI’s responsibility as the payment issuer, to ensure compliance with the UK’s sanctions.

Sweden – raids on “large company” and two arrests in sanctions investigation

Sweden’s Public Prosecutor has issued a press release making public raids conducted this morning at the premises of an unnamed “large company” in Sundsvall.

Two unnamed “people in senior positions” have also been arrested on suspicion of aggravated sanctions violations.

The press release does not include information on the suspected breaches.

Given the web links to information on Sweden’s Russian sanctions included in the press release, the investigation is very likely to relate to suspected breaches of the EU’s Russian sanctions.

United Kingdom – corporate registry moves to dissolve entities sanctioned by the U.S. as related to the IRGC

The OCCRP has reported on actions taken by England’s Companies House to dissolve the company, and crypto exchange, Zedxion Exchange Ltd.

Zedxion is an SDN under U.S. sanctions for its links to Babak Zanjani (another SDN) and the IRGC.

Companies House has posted a notice on the pages for Zedxion stating:

The registrar is intending to take, or has taken, steps to strike off this company under section 1002A of the Companies Act 2006. This relates to information or a statement in an application for incorporation that is misleading, false or deceptive.

As per the OCCRP the false, misleading or deceptive information appears to relate to the identification information provided as to the shareholder, and person of significant control, of Zedxion.

Spain – raids and three arrests relating to alleged transfers of villas by a designated person

On Monday the Spanish authorities conducted raids on multiple properties in Mallorca alleged to be owned by or for Nikolai Kolesov, a businessman designated under the EU’s sanctions since December 2024.

Three people have been arrested including a lawyer and someone who stood as proxy as part of the alleged transactions.

The raids were conducted on the homes of those arrested and at the villa properties.

The blog’s 700th post – sanctions enforcement milestones reached

With today’s post on convictions in Germany, the blog has reached the milestone of 700 posts.

The post also takes European Sanctions Enforcement over several other milestones:

  • The €20m confiscated is Europe’s seventh largest sanctions fine/confiscation since 2017. All but one of those from the UK were fines imposed by the Financial Conduct Authority.

  • There has now been more than €500m in fines, penalties or confiscations since 2017.
  • More than a century of jail time has been handed out since 2024, and Germany alone has seen sentences of more than 70 years of jail since 2017.

Enforcement across Europe is trending upwards.

Portugal – Public Prosecutor opens 26 investigations into Russian sanctions breaches

It is being reported that the Portuguese Public Prosecutor’s Office has opened 26 criminal investigations into possible Russian sanctions breaches since the start of the full-scale war in Ukraine.

No further information is provided as to the nature of the alleged offending or the current state of progress of those investigations.

It is also reported that the Security Intelligence Service (SIS) has “been monitoring and assessing presence in Portugal of elements connected, directly or indirectly with Vladimir Putin’s regime”.

Switzerland – FINMA revokes licence of merchant bank for AML and sanctions compliance failures

The Swiss financial services regulator has put out a press release announcing its decision, taken several weeks ago, to revoke the licence of MBaer Merchant Bank AG for AML and sanctions compliance failings.

Initially the bank appealed this decision.

In the wake of the US regulator FinCEN announcing that it proposed to name the bank as a “financial institution of primary money laundering concern”, the bank has withdrawn the appeal against FINMA’s decision, and a liquidator has now been appointed to oversee the bank’s liquidation.

© 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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