Financial Sanctions – Page 14 – European Sanctions Enforcement

August 16, 2023December 9, 2024 by Mark Handley

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.

August 10, 2023January 11, 2024 by Mark Handley

Netherlands – National Bank critical of de Volksbank sanctions compliance

The annual report for de Volksbank N.V. has revealed the results of a sanctions-review by the Dutch National Bank.

The report states:

“Furthermore, de Volksbank has initiated a comprehensive remediation project to enhance the customer screening and transaction screening systems. This project will remediate findings from regulatory testing of our screening systems conducted by DNB in the second half of 2022, and is expected to be finalised in the first half of 2024”.

The report also notes that the DNB had identified compliance failings in the AML and anti-terrorist financing space, and de Volksbank has made a provision of €1 million in anticipation of the expected fine.

August 3, 2023February 9, 2024 by Mark Handley

Germany: BaFin investigating German bank over Iran sanctions

The German financial services regulator, BaFin, has issued a press release confirming an investigation into the money laundering and sanctions compliance of the bank Varengold Bank AG. The particular focus is Iran sanctions.

BaFin has prohibited the bank from processing payment transactions involving Iran, or person or companies resident in Iran. BaFin has also appointed a representative to oversee compliance with this prohibition.

July 20, 2023March 15, 2024 by Mark Handley

UK’s FCA investigating 100 suspected sanctions breaches

The UK’s financial services regulator, the FCA, has published its annual report today for the year ending 31 March 2023.

Included in the report the FCA states that: “We reviewed nearly 100
suspected sanction breaches. We have also introduced a data-led approach to proactively supervise firms to ensure they have appropriate sanctions systems and controls, we also conducted 38 proactive assessments looking at firms’ systems and controls”.

June 26, 2023May 21, 2024 by Mark Handley

Netherlands – two arrested on suspicion of transferring funds to Hamas

The Dutch authorities have arrested two people on suspicion of transferring funds for the benefit of Hamas – an organisation designated under EU sanctions.

The transfers are alleged to have amounted to €5.5 million.

Searches were conducted in Leischendam and Rotterdam including the seizure of cash.

June 26, 2023February 13, 2024 by Mark Handley

France – some charges against Lafarge-Holcim dropped

Further to our earlier posts (here, here, and here) regarding an investigation into whether cement company Lafarge-Holcim breached EU sanctions by making payments to designated persons, it has been announced that the charges relating to financing of terrorism breaches are being discontinued.

The charges relating to crimes against humanity continue.

In October 2022 Lafarge-Holcim had plead guilty to related charges before the US Department of Justice and agreed to pay $778 million.

June 1, 2023January 11, 2024 by Mark Handley

Netherlands – arrest on suspicion of breach of Sanctions Act

The Dutch authorities have conducted searches at residential and business premises in Oegstgeest, The Hague and Haarlemmermeer and arrested a 73-year old on suspicion of breaching the EU’s sanctions against Russia.

The man is alleged to have transferred shares in return for payment and paid €19 million in dividends to a Russian company owned or controlled by a designated person under the EU’s sanctions.

May 8, 2023January 11, 2024 by Mark Handley

Switzerland – revised enforcement statistics: 130 cases

Further to our earlier post that the Swiss had nearly 100 sanctions investigations, the Swiss authorities have provided an update.

The number of investigations conducted by SECO (the State Secretariat for Economic Affairs) is now 130, with 29 of those referred for criminal prosecution.

April 8, 2023February 17, 2025 by Mark Handley

Ireland – case referred for criminal prosecution for breach of Russian sanctions

It has been reported today that the Gardaí have referred a case for criminal prosecution to the Director of Public Prosecutions for alleged breaches of the EU’s Russian sanctions.

No further details on the case were reported.

April 4, 2023January 11, 2024 by Mark Handley

Netherlands – fine imposed by regulator (largely) upheld

An unnamed financial services provider had appealed three fines imposed on it by the Dutch National Bank in relation to inadequate AML and sanctions screening in relation to transactions to do with Somalia, Syria and Saudi Arabia.

The fines were €8,000, €5,000 and €10,000 for the three identified breaches.

The fine of €8,000 was reduced on appeal to €7,600 on the basis of delay by the regulator, but the others were upheld.