The UK’s HMRC has today announced the imposition of compound penalties on four UK exporters. Those companies were not named.
Little information is provided but the exports were all either dual-use goods or military goods.
The compound penalties which were imposed between November and December 2022, were:
An individual has today been convicted of exporting €11,000 in physical currency from Germany to Russia in breach of Art 5(i)1 of EU Regulation 833/2014.
The individual asserted that he was carrying the currency for the purposes of receiving dental treatment in Kaliningrad.
The judgment takes the view that the exception permitting some cash to be carried “should … be interpreted narrowly”, and that the Commission’s FAQs are a means of discerning the intention of the legislator.
He was fined €4,500 and the balance of the cash above the €500 threshold was confiscated.
The UK’s Financial Conduct Authority has issued a Final Notice to Al Rayan Bank PLC in relation to its failings with customer due diligence, including a lack of due diligence documentation for customers linked to sanctioned countries, or the lack of appropriate enhanced due diligence.
The bank was fined £4,023,600.
The UK’s Financial Conduct Authority has issued a Final Notice against Guaranty Trust Bank (UK) Limited.
The fine was £7,671,800.
The reported failings include a lack of screening against OFSI’s Consolidated List despite policies and procedures requiring such screening. Thousands of accounts had also been established in a way that screening was only done at onboarding and not periodically. Further 90% of resolved sanctions “hits” did not include information or documents demonstrating the basis for the resolution.
The Luxembourg financial services regulator, the CSSF, has announced today the imposition of a fine of €1.56 million on Banque Degroof Petercam Luxembourg SA.
The fine followed an inspection which started in September 2019, and relates to compliance failings in the context of AML and terrorist financing, and a failure to adequately screen clients for inclusion on EU sanctions lists.
The CSSF noted that remedial steps have been taken by the bank since the inspection of 2019/2020.
It has been reported that Dmitry Mazepins, a designated person under the EU’s Russian sanctions has been fined €500,000 for unlawfully removing a frozen asset from Italy.
The asset in question was the yacht Aldabra which is said to have been sailed to Tunisia out of the reach of the EU’s sanctions.
The UK’s HMRC has today announced penalties imposed on twelve exporters. The exporters are not named and the details of the offending are limited but the exports all related to either dual-use or military goods.
The penalties imposed were:
The Latvian authorities have announced the conviction of a man on charges of importing goods from Belarus in breach of the EU’s sanctions.
The goods in question were railway sleepers and 8kg of nails.
The fine imposed was €5,000. No custodial sentence was imposed, but the man was banned from conducting any import business from Belarus for a year.
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.
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.
