The District Court of Rotterdam has imposed a two-month suspended sentence on an individual for the transfer of €200 to his brother.
The brother was fighting for ISIS in Syria and so the transfer was in breach of EU sanctions.
Netherlands – Dutch National Bank fines trust office for KYC failings
The Rotterdam District Court has heard an appeal against fines imposed by the Dutch National Bank on a trust office.
The fines were of €593,750 and €10,000.
Some aspects of the appeal were upheld and the fines were reduced, but the court agreed with the KYC failings (including related to sanctions screening) and imposed revised fines of €534,375 and €9,000.
UK – OFSI Annual Report: enforcement statistics
OFSI has released its Annual Report for 2018-2019.
In it OFSI reports that it received 99 reports of suspected sanctions breaches with a value of £262 million.
UK – OFSI’s third monetary penalty
OFSI has today imposed a fine of £146,341 against Telia Carrier UK Limited for breaches of the EU’s Syrian sanctions.
The breaches arose out of Telia facilitating telephone calls for SyriaTel which is a designated person under the EU sanctions. The phone connections were treated as “economic resources” for the purposes of the sanctions.
The fine in this instance was reduced from £300,000 after Telia opted to seek a ministerial review of OFSI’s penalty.
Netherlands – further ISIS conviction
The Dutch authorities have obtained a further conviction for transfers of small sums of money in breach of the EU’s ISIS sanctions.
The transfers in this instance were of €500 and €950.
The man was given a suspended 5 month sentence with a 2 year probation period.
Luxembourg – regulator imposes fines for sanctions screening failures
The Luxembourg financial services regulator, the CSSF, has today fined Banque Puilaetco Dewaay Luxembourg SA €15,000 for AML and sanctions compliance failings.
The penalty notice noted that the failing was “a temporary deficiency of the ongoing screening system of the client database against sanction lists”, and noted that the deficiency had since been remediated.
UK – FCA imposes fine of £102m
The UK’s Financial Conduct Authority has issued a Decision Notice against Standard Chartered Bank including a fine of £102,163,200.
The fine related to KYC failings in general, with a focus on failure to conduct customer due diligence even in situations where sanctions red flags were evident. The FCA noted a lack of financial crime risk, and concerns as to the quality of the advice being given.
A particular focus were the UAE branches of the bank, and also export financing in relation to the export of military goods.
France – banking regulator finds breaches but does not fine
The Sanctions Commission of the French Banking Regulator (the ACPR) has published its decision from disciplinary proceedings against Raguram International.
Between 2015 and 2017, Raguram had failed to conduct KYC on its customers and failed to incorporate the lists of Eu sanctioned persons into its systems and controls framework.
At the time Raguram had not recognised that its controls environment was defective, but it had subsequently implemented stricter policies and procedures and purchased a compliance solution.
As a result of these steps no fine was imposed.
Netherlands – individual convicted for transfers to ISIS family members
The Dutch authorities have obtained the conviction of an individual for making financial transfers to two family members in breach of the EU’s sanctions against ISIS.
Five transfers were made in total with the largest being €3,500.
The man was given a suspended 100 day prison sentence with a 2 year probation period and 240 hours of community service.
UK – OFSI imposes further financial penalty
OFSI has today imposed a £10,000 penalty on Travelex Limited in relation to a £204 transaction involving the funds of a designated person.
This penalty is factually related to the same transaction as was the subject of OFSI’s first penalty.
While the fine itself is very small, that OFSI has imposed a fine in relation to such a small transaction is perhaps itself of significance.