The Luxembourg financial services regulator, the CSSF, has today fined Banque Puilaetco Dewaay Luxembourg SA €15,000 for AML and sanctions compliance failings.
The penalty notice noted that the failing was “a temporary deficiency of the ongoing screening system of the client database against sanction lists”, and noted that the deficiency had since been remediated.
Her Majesty’s Revenue & Customs (HMRC) has today published details of a compound penalty of £10,234.26 imposed on a UK exporter/trader.
The penalty was in relation to unlicensed trading of body armour. The goods were not exported from the UK, but the transaction involved a UK national.
The Notice to Exporters noted that the Export Control Order 2008 requires a trade control licence when certain goods are exported from a country other than the UK, and that exporters should be aware that trafficking and brokering military goods outside the UK will need a trade control licence, even if the goods do not pass through the UK.
The UK’s Financial Conduct Authority has issued a Decision Notice against Standard Chartered Bank including a fine of £102,163,200.
The fine related to KYC failings in general, with a focus on failure to conduct customer due diligence even in situations where sanctions red flags were evident. The FCA noted a lack of financial crime risk, and concerns as to the quality of the advice being given.
A particular focus were the UAE branches of the bank, and also export financing in relation to the export of military goods.
The UK’s HMRC has today announced that it has fined a UK exporter £82,152.33 for the unlicensed exports of military goods.
The identity of the exporter, and of the destination for the goods, were not published.
Three managers of Sig Sauer, the arms manufacturer have been convicted (after guilty pleas) of the unlicensed export of small arms to Colombia. See our earlier post.
One manager was fined €600,000 and given an 18-month suspended prison sentence. Another was fined given a 10-month suspended sentence and also fined €600,000. A third was fined €60,000 and given a 10-month suspended sentence.
The company itself was fined €11 million.
OFSI has today imposed a £10,000 penalty on Travelex Limited in relation to a £204 transaction involving the funds of a designated person.
This penalty is factually related to the same transaction as was the subject of OFSI’s first penalty.
While the fine itself is very small, that OFSI has imposed a fine in relation to such a small transaction is perhaps itself of significance.
The Dutch District Court in Limburg has convicted two companies and three individuals of unlicensed exports of gas turbine machinery to Iran.
The companies were Euroturbine BV, and its Bahraini subsidiary, and they were fined €500,000 and €350,000 respectively.
The exports were routed via indirect channels to and mask the destination.
The individuals were respectively sentenced to 12 months in jail, of which 11 months were suspended and 240 hours of community service; 8 months in jail, of which 7 months were suspended and a community service of 200 hours. The third individual , a company employee, was sentenced to 180 hours of community service.
A fourth individual had earlier pled guilty and been sentenced to 120 hours of community service.
It was reported today that the Penal Court of Antwerp has convicted three Belgian companies and associated individuals of breaching the EU’s Syrian sanctions by exporting 168 tons of isopropranol which is a dual-use product.
AAE Chemie Trading was conditionally fined €346,443 with €50,000 effective. Anex Customs was fined €500,000 of which €100,000 is effective and Danmar Logistics were fined between €75,000 of which €50,000 is effective
Rolf Rippen, the manager of AAE Chemie Trading was sentenced to four months in jail suspended, while Herman Van Landeghem, a manager of Anex Customs and Danmar Logistics, received a 12-month custodial sentence.
It has been announced today that the UK’s HM Revenue & Customs has issued compound penalties ranging between £1,000 and £4,000 to 3 separate UK Exporters.
These related to unlicensed exports of dual use goods and export breaches controlled by The Export Control Order 2008.
The UK’s Official of Financial Sanctions Implementation has today imposed its first financial penalty.
The penalty relates to a single transaction of £200 relating to funds of a designated person under the Egyptian sanctions.
The bank, Raphaels Bank, self reported to OFSI.
The initial fine was £10,000 reduced to £5,000 in acknowledgment of the self-reporting.
