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.
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.
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.
Following raids in Riga and Tallinn by the Latvian Security Police, in close cooperation with the Estonian Internal Security Service (ISS), it was reported today that two individuals have been fined by the Latvian courts for breaching the EU’s Russian sanctions.
The breaches involved making funds available, through contracts involving broadcasting, to a designated person. The individuals (Oleg Solodov and Margus Merima) were each fined €25,000, and a further €3 million was confiscated.
The UK’s HM Revenue and Customs has today announced the imposition of 10 compound penalties in relation to failures to comply with the UK’s export control regulations for dual-use and military goods. The fines were imposed between March and November 2021.
HMRC’s Notice to Exporters can be found here.
In line with HMRC’s standard practice the compound penalties are anonymised and of low value, with little information made available. The information provided is supplied below.
Continue reading “UK’s HMRC imposes 10 fines for export control violations”
Two Danish companies have been convicted of exporting 177,000 tonnes of jet fuel to Syria in breach of the EU’s sanctions.
In total some 33 transactions took place between 2015 and 2017, with the exports routed through Russian companies bound for Syria.
The company Dan-Bunkering was fined DKK 30 million ($4.6m), with a further DKK 15 million of unlawful profits confiscated.
The parent company Bunker Holding was fined DKK 4 million.
The Dan Bunkering CEO was also convicted and given a four-month custodial sentence , suspended pending a one year probation period.
The German Federal Court of Justice has upheld the confiscation of €11 million imposed on Sig Sauer for unlicensed exports of small arms to Colombia.
See our earlier post, for the original fine from 2019.
The exports were made as part fulfilment of a contract by the US government to supply weapons to the Colombian police, but the necessary export licences were not obtained from the German authorities.
The judgment is available here.
OFSI has today issued a second penalty for breach of the EU’s Russian sanctions, again using its civil enforcement powers.
The penalty notice is available here.
The penalty, of £36,393.45, was imposed on Clear Junction Limited. The transactions in this case are the same as those relating to TransferGo, although OFSI makes clear that it was Clear Junction which reported the transactions. It is noteworthy that some of the impugned transactions took place after the first report to OFSI.
OFSI’s notice also makes the point that the breach here was of the EU’s Russian sanctions, and that post-Brexit OFSI will continue to investigate breaches of the EU’s regulations that may have taken place before Brexit.
Today OFSI announced it had imposed a £50,000 financial penalty on TransferGo in the latest example of the use of its civil enforcement powers.
OFSI’s penalty notice is available here.
The fine was imposed in relation to 16 transactions over nearly 2 years valued at just £7,674.77 through which funds were made available Russian National Commercial Bank, which is a designated person under the EU’s Russian sanctions.
TransferGo did not self report but did cooperate with the investigation.
OFSI’s notice makes clear that the RNCB was not the intended beneficiary of the transactions, rather the recipients of the transfers were accounts held by non-designated persons with RNCB. OFSI has made clear that as funds held in bank accounts are legally held by the banks, that these transfers all amounted to making funds available to RNCB
