Financial Sanctions – Page 8 – European Sanctions Enforcement

March 23, 2024 by Mark Handley

Cyprus – investigation into potential attempted sanctions circumvention

It has been reported today that the Company Registrar in Cyprus, alongside the Cyprus Bar Association, are investigating an instance of possible Russian sanctions breaches.

The investigation relates to allegations that two days after additions to the OFAC SDN list a Cypriot company newly-filed documents purporting to show corporate rearrangements dating back several years which is accurate and reliable would remove the company from the impact of the US listing.

It is unclear whether the investigation relates to any breaches of the EU’s sanctions.

March 23, 2024 by Mark Handley

Germany – seizure of cargo of Russian timber

It is being reported that the German customs authorities have seized a cargo of Russian timber bound for the United States valued at over $40 million.

The seizure arose because the vessel carrying the timber to the United States was required to call into the port of Rostock due to technical difficulties.

The customs authorities have taken the view that this amounts to an import into the EU of sanctioned timber products from Russia. This determination is currently the subject of an appeal.

The Canadian company, Atlantic Ro-Ro Carriers owns the vessel involved.

It is also being reported that 10% of the cargo is products of a company owned or controlled by a person designated under the EU’s sanctions.

March 15, 2024March 15, 2024 by Mark Handley

European sanctions enforcement: the last two months

This blog has been live now for just over two months.

During that time and by way of recap, a number of states have provided updated enforcement statistics in that period (Finland, Switzerland, Latvia), but the period has also seen a significant volume of new enforcement activity:

Continue reading “European sanctions enforcement: the last two months”

March 13, 2024 by Mark Handley

Ireland – four Gardaí investigations into Russian sanctions breaches

It has been reported in Ireland that four suspected breaches of Russian sanctions have been reported to the Gardaí for investigation.

No further details on the investigations or the alleged conduct were reported.

See our earlier post for a case for criminal prosecution being referred by the Gardaí to the Director of Public Prosecutions.

March 13, 2024 by Mark Handley

Switzerland – a new criminal investigation for sanctions breaches and a further SECO fine

It is being reported today that the Office of the Attorney General of Switzerland has commenced a criminal prosecution in a case handed to it from SECO.

Neither the name of the company involved, nor the sector, nor the alleged offences have been made public.

It is also being reported that the Office of the Attorney General has rejected a second case referred to it by SECO.

The same report quotes SECO as saying that it has received 240 reports of possible sanctions breaches and had imposed 10 penalties. As in our earlier post , last month SECO was quoted as saying it had imposed 9 fines, indicating that a further fine has been imposed since. No further details are known of this fine.

March 12, 2024 by Mark Handley

France – investigation into bank’s Sudan transactions

It is being reported today that BNP Paribas remains the subject of an ongoing investigation by the Paris Prosecutor’s office in relation to allegations of complicity in crimes against humanity, torture and genocide arising from the financial services it provided to the government of Sudan between 2002 and 2008.

BNP’s Swiss subsidiary is also the subject of the investigation.

BNP Paribas has previously pled guilty to US sanctions charges, and the Swiss regulator FINMA has previously punished BNP Paribas Suisse.

While the relevant limitation period for sanctions offences in France has expired, the case is a reminder that same sanctions breaches can potentially give rise to liability for other offences.

March 4, 2024 by Mark Handley

Denmark – investigation into importation of aviation fuel from India in potential breach of Russian sanctions

It has been reported that the Danish Business Authority is currently investigating the Danish shipping company Hafnia for possible breaches of the EU’s Russian sanctions.

The allegations relate to the importation in October of 30 million litres of aviation fuel from a refinery in India which may be owned or controlled by designated persons.

Hafnia is reported to have denied the allegations and stated that it acts in full compliance with all relevant laws and regulations.

February 20, 2024 by Mark Handley

France – €120 million villa allegedly owned or controlled by GazpromNeft seized by French prosecutors

The Parquet de Paris (Paris Prosecutor’s Office) has seized a villa valued at €120 million in the south of France, and the shares of the company that is the registered owner of the villa.

The Paris Prosecutors allege that the villa is really owned or controlled by GazpromNeft, the Russian state-owned gas company which is designated in the EU and so subject to an asset freeze.

The seizure forms part of a ongoing investigation.

February 14, 2024 by Mark Handley

Finland – conviction of Russian national for breach of the EU travel ban

In a rare example of the enforcement of the travel ban imposed on designated persons, a court in Finland has convicted the Russian national Yan Petrovsky for travelling into Finland under an assumed alias, Voislav Torden, in 2022 and 2023.

Petrovsky was sentenced to 40 days in jail, and ordered to pay a fine of €80.

February 9, 2024March 19, 2024 by Mark Handley

Latvia – further sanctions enforcement statistics including seven convictions

The Latvian authorities have provided a further update to their enforcement efforts. As reported:

- 281 sanctions-related suspicious activity reports in 2022
- 510 sanctions-related suspicious activity reports in 2023
- 310 criminal cases commenced
- 22 prosecutions in which the trial has started
- 7 convictions to date.

Of the convictions, all involved guilty pleas and all involved Latvian nationals. The highest penalty related to the export of a luxury car, and the fine was €170,000.

The conduct prosecuted included in relation to the sale of a professional footballer to a club owned by a company designated under Belarus sanctions, and the provision of content to the Russian Federal News Agency.

UPDATE: It has now (18 March 2024) been reported that the fine imposed in relation to providing economic resources to the Russian news agency in the form of employment services, was €15,500.