Fine – Page 19 – European Sanctions Enforcement

April 9, 2019March 15, 2024 by Mark Handley

UK – FCA imposes fine of £102m

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.

April 3, 2019March 15, 2024 by Mark Handley

UK – HMRC fines exporter £82,152.33

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.

April 3, 2019January 11, 2024 by Mark Handley

Germany – company fined €11 million and three managers sentenced for unlicensed exports

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.

March 8, 2019March 15, 2024 by Mark Handley

UK – OFSI imposes further financial penalty

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.

February 18, 2019October 31, 2024 by Mark Handley

Netherlands – two companies and three individuals convicted of Iran exports

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.

February 7, 2019January 11, 2024 by Mark Handley

Belgium – convictions for breaching Syrian sanctions

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.

January 25, 2019March 15, 2024 by Mark Handley

UK – HMRC compound penalties for three companies for export control breaches

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.

January 21, 2019March 15, 2024 by Mark Handley

UK – OFSI imposes its first ever financial penalty

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.

December 21, 2018January 26, 2024 by Mark Handley

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.

December 19, 2018February 22, 2024 by Mark Handley

Luxembourg – regulator fines bank for sanctions failings

The Luxembourg financial services regulator, the CSSF, has today imposed a a fine of €55,000 on ANF Luxembourg SA for AML and sanctions compliance failings.

The penalty notice noted failings in compliance in relation to UN sanctions, but does not specify which regime was implicated.