Fine – Page 11 – European Sanctions Enforcement

November 17, 2022September 10, 2024 by Mark Handley

Germany – conviction for importing timber from Myanmar referred to CJEU

A referral to the Court of Justice of the European Union has revealed a conviction in Germany arising from the importation of timber from Myanmar in breach of the EU’s sanctions.

The defendant was convicted and given a sentence of 19 months in prison and a confiscation order of €3,310,902.98 was imposed as well.

The case has been referred to the CJEU because the defendant argues that the timber in question should properly be seen as having been imported from Taiwan, and not Myanmar, because the timber had been processed in Taiwan.

Update: The CJEU case was registered on 8 February 2023.

November 11, 2022January 11, 2024 by Mark Handley

Romania – fines and confiscations confirmed

The President of Romania’s ANAF (National Agency for Fiscal Administration) has confirmed that ongoing results of the organisation’s sanctions enforcement actions.

Without providing details he stated that fines of 280,000 lei (c. €56,000) had been imposed and amounts of 13.171 million lei (c. €2,650,000) had been confiscated.

No further details on these enforcement actions were published.

October 10, 2022March 19, 2024 by Mark Handley

Latvia – confiscation of $4m as part of investigation of UN sanctions breaches

Further to our earlier post, the Latvian VDD is investigating arms sales to an unnamed African country allegedly in breach of UN sanctions.

As part of that investigation the VDD has today announced the confiscation of $4m uncovered in an offshore account.

September 27, 2022March 15, 2024 by Mark Handley

UK’s OFSI imposes EU Russian sanctions civil penalty

OFSI today announced that it had imposed a civil penalty for breach of the UK’s Russian sanctions.

The penalty notice is available here.

The fine was imposed on Hong Kong International Wine and Spirits Competition Limited (HKIWS), and was just £30,000.

The conduct in question was the receipt of funds and goods from a designated person. The goods in question were wine bottles. HKIWS was also found to have made “economic resources” available to a designated person. This was in the form of publicity, and illustrates OFSI’s wide view of what amounts to the making available of an economic resource.

August 12, 2022February 22, 2024 by Mark Handley

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.

July 26, 2022February 22, 2024 by Mark Handley

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.

July 15, 2022March 15, 2024 by Mark Handley

United Kingdom – FCA fines company £2m for sanctions failings

The Financial Conduct Authority in the UK has issued a Final Notice to TJM Partnership Limited imposing a financial penalty of £2,038,700 of which £1,198,277 was for disgorgement.

Included in the failings were a failure to properly perform sanctions screening against customers.

June 23, 2022March 15, 2024 by Mark Handley

United Kingdom – bank fined by FCA for sanctions compliance failures

The UK’s Financial Conduct Authority has fined Ghana International Bank Plc for sanctions compliance failures, including a lack of periodic screening, only screening after onboarding had been completed, and an insufficiently detailed or practical sanctions policy.

The bank was fined £5,829,900 after a 30% reduction for cooperation and early settlement.

June 8, 2022March 15, 2024 by Mark Handley

UK – convicted exporter to Iran ordered to pay £700,000

HMRC has announced that British national Alexander George has been ordered to pay £700,000 in a confiscation order issued by the Southwark Crown Court. The funds are the proceeds of crime related to his conviction for exporting parts for jet fighters to Iran.

For more on his conviction back in 2018 see our earlier post.

May 19, 2022March 15, 2024 by Mark Handley

UK’s OFSI imposes fine for breach of Syrian sanctions

OFSI has today announced a civil penalty of £15,000 against Tracerco Limited for a breach of the EU’s Syrian sanctions.

OFSI’s Penalty Notice is available here.

The breaches related to airline tickets valued at £2,956.43 purchased for a Tracerco employee through a travel agency. The airline in question, however, was Syrian Arab Airlines which is designated under the EU’s sanctions.

OFSI, therefore, concluded that purchasing the tickets amounted to making funds available to a designated person. OFSI also commented, in relation to the requirement that it showed Tracerco either knew or had reasonable grounds to suspect that the transactions would breach the regulations, that operating in the region was sufficient to satisfy this requirement.