Czechia – investigation launched into Austrian bank for suspected Russian sanctions breaches

The National Anti-Terrorism Centre of Czechia has initiated an investigation into the activities of the Austrian Raiffeisen Bank International due to its subsidiary’s operations in Russia.

An earlier complaint against Raiffeisen Bank had been filed by the Association for Citizens’ and Entrepreneurs’ Rights.

Police have confirmed that the Anti-Terrorism Centre is conducting an investigation regarding the banking group. However, no further details were disclosed.

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.

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.

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.

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”.

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.

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.

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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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