The UK’s National Crime Agency has applied to confiscate £1.1m in frozen funds owned or controlled by Petr Aven on the basis that the funds in question are the proceeds of crime for being the proceeds of suspected breaches of the UK’s Russian sanctions.
It is being reported that the funds were first frozen by a court order in May 2022. The money is said to have been used in transactions by Ekaterina Kozina, Petr Aven’s wife, and Stephen Gater, Aven’s “representative”.
As part of the press article (behind a paywall) on the recent fines against Novatek Green Energy and Geleo (see our post here), the Polish authorities have also provided an update on their enforcement activity more broadly.
Certainly the figure for total fines does not include the fine against Novatek Green Energy (which was 12 million zloty), but it is also a little unclear whether or not the figure includes the fine against Geleo (which was 4m zloty).
The report also notes that most of the 20 penalties have been imposed in 2024, with only two imposed by the end of 2023 for a combined total of 71,000 zloty (c. $17,700).
These enforcement actions appear to relate to a mix of EU and the separate Polish sanctions.
No information has been provided as to the conduct which gave rise to the fines, or who the fines were imposed on.
Now updated from the post first published on 28 June.
It is being reported (behind a paywall) that the Malopolska Customs and Tax Office of Krakow has imposed fines of 12 million zloty (c. €2.78m) against Novatek Green Energy and 4 million zloty (c. €927,000) against employee-owned company Geleo.
The fine against Geleo was imposed on 31 May. It was for breach of the relevant asset freeze and for circumvention of Polish sanctions. The transaction in question was the purchase, for €1, of 100% of the shares in Novatek Green Energy from the Swiss company Novatek Gas and Power GmbH, which in turn is a direct subsidiary of the Russian company OAO Novatek.
The fine against Novatek Green Energy was imposed on 25 June, and was imposed for multiple transactions in breach of the imposed asset freeze.
With particular thanks to Dr Marcin Łukowski who provided a copy of the relevant article.
As part of its Annual Report, the Unità di Informazione Finanziaria per l’Italia within the Bank of Italy has announced investigations into suspicions of illicit money flows from Italy to Russia via third countries.
No further details are available at this time including the amounts at stake, the identities of the third countries, or whether a referral has been made to the criminal authorities.
It is also unclear whether the transfers are alleged to have been made for or on behalf of designated persons.
The post below has been updated on 17 June 2024 after the helpful input from the Sanctions Unit of the Dutch Ministry of Foreign Affairs:
Further to our earlier post, in late 2021 the Dutch Court of Appeal sentenced an individual to a six month custodial prison term for a number of offences including for making a payment in breach of the EU’s ISIS sanctions.
In his advice to the Dutch Supreme Court has upheld the Attorney General has advised that the convictions for terrorist financing and breaching the Dutch Sanctiewet 1977 be upheld, but that the conviction for money laundering be remanded to the Court of Appeal.
The facts relate to the transfer of €471 from an individual to his brother who was in Syria as part of ISIS. The defence sought to argue that the man did not have the required intent to support terrorism, or knowledge that the funds had benefitted ISIS.
As stated by the Attorney General at [2.9]:
“With regard to the violation of the provision of Article 2 of the Sanctions Act 1977, the offense proven under 2, the suspect’s intent does not have to be aimed at non-compliance with the legal regulations referred to in the finding of proof. The suspect’s intention must be aimed at ensuring that the money ends up indirectly with (a) terrorist organization”.
Further to our earlier post regarding an investigation by the Danish Business Authority into allegations that the Danish shipping company Hafnia, was importing refined fuels from a refinery in India that may have been owned or controlled by Rosneft (which is a designated person under the EU’s sanctions), it is now being reported (here – behind a paywall), that the Danish Business Authority has concluded its investigation having determined that it could not establish that there had been a breach of Russian sanctions.
As yet the Danish Business Authority has not issued a statement on its website.
It is being reported in Cyprus that two cases have been referred to the Prosecutor’s Office for instituting criminal proceedings. No other information was published on these matters.
In addition, yesterday the Economic Crime Investigation Unit provided updates to the Law Office on the progress with 10 of their ongoing cases, including (as we have previously noted) the investigation into asset transfers allegedly in breach of the EU’s sanctions by Alexei Mordashov.
Further to our earlier post, it is being reported that Estonia’s Office of the Prosecutor General has laid charges against Mati-Dmitri Terestal and Elena Cherysheva on suspicion of breaching the EU’s Russian sanctions.
It is alleged that the defendants received €500,000 funds from a designated person, and made economic resources (in the form of their services) available to a designated person – namely Dmitry Kiselyov, the Director General of Rossiya Segodnya which operated in Estonia as Sputnik.
The Lithuanian Customs Office has announced in a press release the imposition of a fine of € 329,944 imposed upon an unnamed Lithuanian company.
The fine was for purchasing goods from the Russian companies which are designated under the EU’s sanctions.
Lithuanian Customs noted that this was the first enforcement by them of the EU’s sanctions on Russian designated persons.
It is being reported in the UK and in the Netherlands, that the Dutch Ministry of Economic Affairs is investigating whether Roman Abramovich owns or controls the football club Vitesse Arnhem. The allegation of ownership or control is based on a series of financial arrangements and loans.
While those arrangement pre-date the sanctions, if the club was indeed owned or controlled by a designated person its operations since the designation are likely to have been conducted in breach of the asset freeze.
