The French media regulator, Arcom, has issued an order to Eutelsat ordering it to cease the broadcasting of two channels owned or controlled by JSC National Media Group which is a designated person under the EU’s Russian sanctions.
The channels are STS and Kanal 5.
Earlier reports had suggested that Arcom might impose a fine on Eutelsat, but no fine was imposed.
It is being reported that the German Prosecutor’s Office has charged four Russian nationals with making funds available to ISIS in breach of the EU’s sanctions.
One individual was arrested in January of this year and three others in July of 2024.
They are accused of raising €174,000 for ISIS and then sending that to ISIS via various channels.
The UK’s OFSI has published a penalty notice imposing a £465,000 fine on Herbert Smith Freehills CIS LLP (“HSF Moscow”) – a UK LLP which operated as the Moscow office of the law firm Herbert Smith Freehills (“HSF”)
The fine was reduced by half due to prompt self reporting by HSF (all the breaches had been reported by 15 July 2022) and further co-operation in the form of the conduct of an internal investigation.
The breaches of the UK’s sanctions were all done by HSF Moscow between 25 and 31 May 2022. The breaches arose from six payments made to designated persons with a total value of £3,932,392.10. The six breaches were:
This case emphasizes above all the approach that OFSI takes in relation to accounts held at designated banks. In the view of OFSI payments into such accounts, albeit accounts held by non-designated persons, will amount to making funds available to a designated person.
In relation to the payment to a subsidiary of a designated person, OFSI also emphasizes the importance of appropriate due diligence to understand possible issues of ownership and control.
OFSI has published its annual report for the year 2023/2024.
The report provides the following data:
2021/22 – 147 investigations opened (and 101 closed);
2022/23 – 473 investigations opened (and 74 closed); and
2023/24 – 396 investigations opened (and 242 closed).
Of the 396 investigations opened in 2023/24, 288 were as a result of self-reporting with 108 opened through pro-active investigation or other means.
Further, OFSI’s report gives a break down of which sanctions regimes the investigations relate to:
The report also gives a break down of the 242 investigations closed during the year of the report:
The Yearbook of the Prosecutor’s Office in Estonia has published details on its enforcement of sanctions to date.
I thank Siiri Grabbi of the Coop Pank in Tallinn for the reference.
The Yearbook states that eight criminal convictions have been obtained with one also appealed. It does not provide details of the offending or the sentences imposed.
The Yearbook further notes that the Prosecutor’s office currently has more than 100 active criminal cases.
It is being reported that the Polish authorities have responded to a press request by confirming that they have 275 sanctions investigations that are ongoing.
No further information was provided on these investigations. It is unclear how many of these relate to Russian sanctions.
Updated enforcement statistics are being reported (here behind a paywall, and here in summary) for the Dutch Fiscal Intelligence and Investigation Service (FIOD) and from Dutch Customs.
FIOD is reported to have conducted 30 cases in the three years since February 2022, with six resulting in convictions, and twenty investigations ongoing.
Customs are reported to have started 80 cases, with 16 ongoing, and 64 settled with fines of between €500 and €200,000.
In 2024, probably for the first time ever, Europe (meaning the EU, UK, Switzerland and Norway), imposed and obtained a greater number of fines and convictions; a higher total value of fines; and also a higher single largest fine, for sanctions breaches than those imposed by the authorities in the United States.
The US figures combine the enforcement actions taken by OFAC and BIS, as well as criminal convictions secured by the DOJ.
The European figures are taken from this blog.
The US obtained 52 successfully-concluded enforcement actions, while Europe secured 118.
The US (OFAC and BIS combined) imposed fines equivalent to €56.8m, while Europe imposed a total of €88.5m.
The single largest US fine was $20m in relation to Iran sanctions. The largest fine in Europe was the UK’s £29m imposed on Starling Bank.
On 31 January the Rotterdam District Court published its decision convicting an individual of breaches of the EU’s ISIS sanctions.
The individual was sentenced to 90 days in jail, of which 74 days is suspended for 2 years. Community Service of 80 hours was also imposed.
The transfers giving rise to the offences were US$4,350 and 150,000 Syrian pounds.
The individual was also charged with financing of terrorism and human trafficking.
Ireland’s Gardaí (National Police) have confirmed to Global Investigations Review that it has referred two investigations for prosecution for alleged breaches of the EU’s sanctions imposed on Russian in the wake of the full-scale invasion of Ukraine in 2022.
It was also confirmed that the Public Prosecution Service declined to being charges in both investigations.
One such referral to the DPP was reported to have taken place in April 2023.
In March 2024 it was reported that the Gardaí had four investigations ongoing into suspected Russian sanctions breaches, but the status of those further investigations is unknown.
