It is being reported (and here) that on Tuesday the Zentralstelle für Sanktionsdurchsetzung (Central Office for Sanctions Enforcement) conducted raids with 100 officers to enforce a District Court judgment on premises in the Tempelhof-Schöneberg region of Berlin.
The reports also state that the subjects of the raids were two logistics companies, said to be from Russia.
No details of the alleged conduct or Russian sanctions breaches giving rise to the raids has been released.
Luxembourg’s Financial Intelligence Unit (the CRF) has published its Annual Report which includes statistics on sanctions-related SARS and investigations, as well as an indication of funds frozen as part of these investigations.
It is being reported that the UK’s National Crime Agency has completed the confiscation of funds related to Petr Aven.
The sum of £750,000 was confiscated from bank accounts held in the name of Petr Aven’s wife and others.
A sum of cash initially recovered by the NCA from a residence outside London was also confiscated.
The funds were confiscated under the Proceeds of Crime Act 2002.
Updated on 1 August to reflect issuance of NCA’s press release:
The NCA has stated that the funds, totalling £783,827.34 were held for the benefit of Petr Aven although not in his name, and that the breaches of sanctions giving rise to the funds being the proceeds of crime were: “Attempts to relocate the funds, as well as transactions made after March 15 2022 by Aven’s estate manager, Stephen Gater … . These included the payment of salaries to over 20 members of Aven’s household staff, and the sale of a Bentley Bentayga worth £160,000“.
It is being reported that two law firms have been reported by the Solicitors Regulation Authority (SRA) to the UK’s OFSI.
it is alleged that the law firms were facilitating financial transactions valued at more than £300,000. It is unclear whether the conduct relates to designated persons, trade sanctions, or the UK’s prohibitions on Russian investment.
The attention on law firms chimes with the report yesterday that there has been an investigation in Germany relating to a potential breach of the EU’s prohibitions on legal advice.
The German media outlet Südwestrundfunk has conducted a survey of Germany’s state justice ministries, public prosecutors office and the Federal Prosecutor’s Office to compile statistics on recent sanctions investigations in Germany.
The vast majority of these are said to relate to Russian and Belarusian sanctions although enforcement of other regimes is included.
The results are:
This is a total of 1,988 investigations conducted since 24 February 2022. No data were reported for the states of Lower Saxony or Anhalt, so this figure is not complete.
In September last year (see earlier post) it was reported that there were 150 on-going investigations in Germany. The new survey reports a minimum of 176 investigations now reported as ongoing, although many regions did not provide a figure for currently ongoing investigations.
Switzerland’s SECO has updated its Russian and Belarusian sanctions enforcement statistics. The previous update was in February 2024 (see our previous post).
The reported new data states that SECO has brought:
Accordingly, SECO has started 9 new criminal administrative proceedings since February 2024, and imposed 5 new fines since May of this year.
The Polish authorities have released updated enforcement statistics showing changes since those release just a few weeks ago.
The new data confirms:
Further, in response to a Freedom of Information request made on behalf of this blog, the Polish Ministry of Finance has provided the following data (available here: MF do M. Handley’a odpowiedź na wniosek 2879.2024):
No other European country has imposed so many fines for breaches of Russian sanctions.
The Commission de Surveillance du Secteur Financier (CSSF) in Luxembourg has imposed fines of €109,000 and €17,200 for compliance failings on abrdn Investments Luxembourg S.A.
The fine of €17,200 related to failings in relation to AML/CFT, and included in these failings was failure to “perform initial name screenings controls against international and European financial sanctions lists”.
The CSSF had conducted on-site inspections in 2020.
The District Court of Rotterdam has convicted an individual on one count of making funds (€350) available to a person designated under the Dutch Terrorism Sanctions Regulations 2007.
The defendant was acquitted of another charge of making funds available to ISIS on the basis of a lack of evidence that the defendant knew the recipient was connected with ISIS and because the transfer had taken place after ISIS had been largely defeated in Syria.
The individual was sentenced to 60 hours of community service, although this time had already been performed by virtue of a lengthy pre-trial detention.
Lithuania’s Financial Crimes Investigation Service has imposed a fine of €8.23m for breaches of the EU’s sanctions and a fine of €1.06m for breaches of Lithuania’s Law on the Prevention of Money Laundering and Terrorist Financing.
The company fined is UAB Payeer. The press release notes that the company did not cooperate with the investigation and did not provide responses to questions raised.
The investigation commenced after an inspection in 2023 that was conducted after Payeer commenced its operations in Lithuania.
Payeer operated a crypto exchange at Payeer.com which allowed customers to make transfers to or from Russian banks that were designated under EU sanctions.
The AML fine relates to the failure to conduct KYC and the failure to report suspicious transactions.
The press release notes that Payeer had revenues of more than €164m during the 1.5 years of its breaches, but does not note what proportion of this came from prohibited activity.
