France – raids on company shut down large scale exports to Russia in breach of sanctions

France’s La Direction Nationale du Renseignement et des Enquêtes Douanières has issued a press release reporting on raids conducted on a company in Ile-de-France on Thursday and Friday of last week.

The raids by 25 customs officers came after a 10-month investigation. The conduct is stated to amount to exports valued at several 10s of millions of Euros, and to have involved 100s of false customs declarations involving several dozen different exporters each using the services of the raided customs agent.

The company had advertised on the darkweb that it could provide a turnkey sanctions evasion service.

The French authorities acknowledged the help from reports from other European countries and noted the investigation highlighted “statistical anomalies, notably an exponential growth of exports of the company in question to third countries bordering Russia”.

 

European Sanctions Enforcement – milestone of over 2000 announced and active investigations reached

With the recent news that Finland has increased the number of its ongoing investigations, Europe (meaning the EU, the UK, Switzerland, etc) has reached the milestone of over 2,000 ongoing and public sanctions enforcement investigations being undertaken by regulators and prosecutors.

No doubt there are other investigations which are ongoing in the countries shown on the graph, and no doubt there are investigations ongoing in countries not shown and which remain confidential.

How many of these will be dropped due to inconclusive evidence or exculpatory evidence, and how many will lead to a conviction or fine or acquittal is impossible to say.

It is, without question, an unprecedented level of enforcement.

 

France – seizure of apartment owned by Russian designated person

Le Monde has reported that the French authorities have seized a property in Paris belonging to designated person Dmitry Peskov, President Putin’s  spokesperson.

The seizure took place in December 2023. A villa in south-west France was seized at the same time with it said to belong to Artur Ocheretny, who is married to President’s Putin’s former wife. Mr Ocheretny is not designated under the EU’s sanctions.

It is being reported that the seizures are part of investigations relating to allegations of money laundering.

France – investigation into bank’s Sudan transactions

It is being reported today that BNP Paribas remains the subject of an ongoing investigation by the Paris Prosecutor’s office in relation to allegations of complicity in crimes against humanity, torture and genocide arising from the financial services it provided to the government of Sudan between 2002 and 2008.

BNP’s Swiss subsidiary is also the subject of the investigation.

BNP Paribas has previously pled guilty to US sanctions charges, and the Swiss regulator FINMA has previously punished BNP Paribas Suisse.

While the relevant limitation period for sanctions offences in France has expired, the case is a reminder that same sanctions breaches can potentially give rise to liability for other offences.

France – €120 million villa allegedly owned or controlled by GazpromNeft seized by French prosecutors

The Parquet de Paris (Paris Prosecutor’s Office) has seized a villa valued at €120 million in the south of France, and the shares of the company that is the registered owner of the villa.

The Paris Prosecutors allege that the villa is really owned or controlled by GazpromNeft, the Russian state-owned gas company which is designated in the EU and so subject to an asset freeze.

The seizure forms part of a ongoing investigation.

France – Anti-Terrorism Prosecutor advances sanctions charges against Lafarge and individuals

On Friday France’s National Anti-Terrorism Prosecutor’s Office applied to the Paris court to have charges of terrorist financing, and breach of the relevant EU sanctions heard against Lafarge Holcim and nine individuals.

This criminal trial would go ahead before the trial of Lafarge on allegations of crimes against humanity after the Court of Cassation ruled last month that those charges should proceed.

For our earlier posts on the Lafarge matter see here.

France – some charges against Lafarge-Holcim dropped

Further to our earlier posts (here, here, and here) regarding an investigation into whether cement company Lafarge-Holcim breached EU sanctions by making payments to designated persons, it has been announced that the charges relating to financing of terrorism breaches are being discontinued.

The charges relating to crimes against humanity continue.

In October 2022 Lafarge-Holcim had plead guilty to related charges before the US Department of Justice and agreed to pay $778 million.

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The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

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