France – bank fined €50m for sanctions compliance failings

The ACPR in France has today announced the imposition of a fine of €50m against Banque Postale.

This is the largest fine imposed in France to date.

The fine was imposed for sanctions compliance failings and in particular the ability of designated persons to transfer funds through Banque Postale, even when not a customer, by “money order”.

Banque Postale has indicated an intention to appeal the fine.

Netherlands – company convicted of breach of Russian sanctions

The District Court of Amsterdam has convicted a company on multiple charges of exporting military goods for a Russian end user. The intended Russian recipient of the exports was named as JSC Global Security, but the name of the convicted Dutch company was anonymised.

The goods  (mostly bullet proof vests and other military equipment) were stopped at Schiphol airport and had been brought from South Africa.

The company was fined €30,000 (half suspended for 2 years).

Netherlands – Dutch National Bank fines of €170,000 upheld on appeal

The District Court of Rotterdam has upheld fines of €170,000 imposed by the Dutch National Bank on a payment services provider for breaches of Dutch sanctions law and AML rules.

The appeal was largely based on arguments that the internal compliance function had adequately performed its function. The court was highly critical of this argument, noting the lack of due diligence and periodic training.

Netherlands – criminal fine imposed for breach of Russian sanctions

The Dutch Public Prosecution Service has obtained a criminal fine of €50,000 against an unnamed Dutch freight solutions company.

The company had sought to ship radar equipment for Sukhoi jet fighters from Malaysia to Russia. The consignment was intercepted at Schiphol Airport. The sale was in breach of both European export controls, as the products were included on the EU’s Military List, and in breach of Russian sanctions which would have prohibited the granting of an export licence.

No licence had been applied for.

An individual was acquitted of a related offence.

Netherlands – fine of €100,000 imposed on payment services provider

In 2015 the Dutch National Bank had imposed a financial penalty of €125,000 on an unnamed payment services provider for failings in relation to sanctions and PEP screening as part of a review by the bank.

The payment services provider appealed the decision.

On appeal to the District Court of Rotterdam the penalty was upheld but the fine reduced to €100,000.

The National Bank had originally calculated the fine as €550,000 which was then reduced due to the financial condition and size of the defendant.

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