Germany – Munich prosecutor investigates alleged sanctions breaches

It has been reported that the Munich state prosecutor has conducted comprehensive raids at the residence of a Russian citizen and four other suspects.

The Russian national is suspected of having recruited a security firm to observe properties in Upper Bavaria financially linked to him, and that the payments made to the firm were in breach of the asset freeze imposed on this designated person.

Also being investigated are the security firm and its staff.

The designated person has been named as Alisher Usmanov but this is a different investigation to the one we have separately reported.

 

Netherlands – 30 month custodial sentence for breach of ISIS sanctions

The Rotterdam District Court has imposed a 30-month custodial sentence on an individual relating to a two-year period in which financial transfers of approximately $140,000 were made in breach of EU sanctions against ISIS and Al Qaeda.

The transfers were related to efforts to smuggle Dutch women who had travelled to Syria and Iraq to be part of ISIS out of that region and back to the Netherlands.

 

Luxembourg – regulator fines bank for sanctions compliance failings

The Luxembourg financial services regulator, the CSSF, has today imposed a a fine of €145,000 on Unzer Luxembourg SA for AML and sanctions compliance failings.

The penalty notice noted that the failings, including in sanctions screening, were identified as part of an on-site inspection in 2020 and 2021, and noted that the lack of a fine took into consideration the bank’s efforts at remediation.

Luxembourg – regulator reprimands but does not fine for sanctions failings

The Luxembourg financial services regulator, the CSSF, has today imposed a reprimand on Banque J Safra Sarasin (Luxembourg) SA for AML and sanctions compliance failings.

The penalty notice noted that the failings, including in sanctions screening, were identified as part of an on-site inspection in 2019, and noted that the lack of a fine took into consideration the bank’s efforts at remediation.

Luxembourg – regulator fines banks for AML and sanctions failings

The Luxembourg financial services regulator, the CSSF, has today fined BEMO Europe Banque Privée SA €356,000 for AML and sanctions compliance failings.

The penalty notice noted that the failings, including in sanctions screening, were identified as part of an on-site inspection in 2020, and noted that the size of the fine took into consideration the bank’s efforts at remediation.

Netherlands – 18 month sentence for exports to Iran

The Dutch Supreme Court has denied an appeal against an 18-month custodial sentence against an individual for his role in  seven exports of goods to the National Iranian Gas Company which is a designated person under the EU’s sanctions.

The shipments were made via Turkey or Dubai and the defence argued in the appeal that this was not “indirectly” making economic resources available to a designated person. The Supreme Court disagreed.

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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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