Tag: Iran

Posted on by Mark Handley

Spain – sanctions-related investigation into origins of imported diesel

It has been reported that the Spanish National Anti-Fraud Investigation Office, and competition authorities, have opened an investigation into the importation of diesel to Spain from Turkey and Morocco.

The suspicion being investigated is whether the diesel actually originates from Syria, Russia and/or Iran.

The investigation is reported to have been commenced in late 2024.

As further reported: “Several of the companies that were accused of bringing oil from Morocco due to their price advantage as they are of Russian origin in 2023 have either been disqualified or are currently involved in legal proceedings for fraud“.

Posted on by Mark Handley

United Kingdom – prosecution for exports of military goods to Iran, Libya, South Sudan, Sudan and Syria

As first reported by Global Investigations Review (behind a paywall), the UK is prosecuting two individuals for the suspected export of military goods to a range of countries including Iran, Libya, South Sudan, Sudan and Syria.

The defendants David Greenhalgh, 67, and Christos Farmakis, 47, pled not guilty to 17 charges at Southwark Crown Crown on 13 June.

The exports are said to have taken place between 2009 and 2016, with the prosecution underscoring the absence of limitation periods in the UK.

As stated by GIR:

“The defendants allegedly helped ship fighter jets, radar systems, missiles and ammunition to Libya; “battle tanks and associated spare parts”, AK-47 rifles, anti-tank missiles and ammunition to South Sudan; missiles, launchers and rocket-propelled grenades to Syria; and Pechora S-125 surface-to-air missile systems, radar equipment and MiG-29, Su-25 and Su-27 fighter jets to Sudan. …

Farmakis is further accused of being involved in the illicit supply of 5,500 AK-47 rifles and 100,000 tonnes of ammunition to Syria, as well as 25,000 pistols to an unnamed country and unspecified quantities of AK-47 rifles to South Sudan and Iran. 

Greenhalgh is separately accused of helping to export Mi-24V attack helicopters to Sudan”.

Trial has been set for April 2026. 

Posted on by Mark Handley

Italy – seizures against Iranian company associated with Russia

It has been reported (here and here), that in early June the Italian police conducted seizures in Milan against the “Iranian” company Irital Shipping Lines.

The seizures involved assets of over €1m.

The reported reason was “Iran’s military support for Russia’s aggression against Ukraine”.

No public statement has been made by the Italian authorities, and it is unclear what is the precise nature of the allegations.

Posted on by Mark Handley

United Kingdom – enforcement update from the OFSI annual report for 2023/24

OFSI has published its annual report for the year 2023/2024.

The report provides the following data:

2021/22 – 147 investigations opened (and 101 closed);

2022/23 – 473 investigations opened (and 74 closed); and

2023/24 – 396 investigations opened (and 242 closed).

Of the 396 investigations opened in 2023/24, 288 were as a result of self-reporting with 108 opened through pro-active investigation or other means.

Further, OFSI’s report gives a break down of which sanctions regimes the investigations relate to:

  • 347 to Russian sanctions;
  • 21 to Libyan sanctions;
  • 9 to Iran sanctions; and
  • 19 across the other regimes.

The report also gives a break down of the 242 investigations closed during the year of the report:

  • 133 closed with a finding of no breach and sending a “No Further Action” letter;
  • 18 closed with a finding there was a breach and sending a “Warning” letter;
  • 1 closed with a finding of a breach and a referral to a regulator;
  • 1 closed with an OFSI public disclosure;
  • 61 closed without a final determination that there was a breach and sending a “No Further Action” letter; and
  • 28 investigations closed for “Other” reasons.

Posted on by Mark Handley

United Kingdom – HMRC has opened 65 trade sanctions investigations since 2022

In a letter written from the UK’s HMRC (the body with primary responsibility for the criminal enforcement of trade sanctions) to Parliament’s Treasury Select Committee, HMRC has provided significant information on its recent enforcement efforts.

YearNumber of investigations opened
20210
202214 (all relating to Russian sanctions)
202322 (20 relating to Russian sanctions)
202429 (27 relating to Russian sanctions)

Of those 65 investigations, HMRC has confirmed that 30 remain live of which 27 relate to Russian sanctions.

The letter tabulates the six fines imposed to date for breaches of the Russian sanctions, and in relation to the largest single fine of £1,000,000 imposed in August 2023 (see our earlier post), the letter notes that this fine relates to “brokering and technical assistance” and not to an actual export.

HMRC’s letter also states that a previously published compound penalty of £1,000 from September 2023 (see our earlier post) was actually for a breach of the UK’s Iran sanctions despite being described at the time as “relating to the attempted export of Dual Use goods”.

HMRC’s letter also states that in October 2024 it referred a case for possible prosecution to the Crown Prosecution Service.

Posted on by Mark Handley

UK – extradition to the US for person suspected of Iran sanctions breaches

A press release from the  US Department of Justice records that an individual, Saeid Haji Agha Mousaei, was arrested in the UK on 24 January 2023 pursuant to an Interpol diffusion notice.

Mr Mousaei was then subsequently extradited to the US where he faces multiple charges arising from the alleged supply of “controlled electronics with military applications, including signals equipment like oscilloscopes and spectrum analyzers, for export and re-export to Iran”.

It is alleged that false documentation was prepared which indicated that the goods were to remain in countries such as the UAE and Armenia, but the goods were all transshipped to Iran via the UAE.

Posted on by Mark Handley

Poland – investigation and charge in relation to dual-use exports to Iran

It is being reported by Reuters that the Polish state-owned company WSK Poznan is being investigated by the National Prosecutor’s Office and the Internal Security Agency on suspicion of supplying parts to Iranian manufacturer, Motorsazan Company, which were then incorporated into drones used by Russian combat forces in Ukraine.

The National Prosecutor’s Office is also reported to have charged the CEO of the company in relation to the export of dual-use goods.

Another report states that the investigation has been ongoing for two years, and notes that the Polish National Prosecutor has denied evidence that parts were used for drones and stated that the investigation relates more to the sale of fuel pumps to Iran.

 

Posted on by Mark Handley

The enforcement of sanctions circumvention in Europe

Sanctions circumvention. It is one of the key topics of the moment.

It is a routine question for people to ask which countries provide a circumvention risk. It is also a common perception that enforcement of sanctions circumvention is lacking.

Based on the material in this blog we have listed out below the more than 40 examples where of recent enforcement of sanctions circumvention on a third-country by third-country basis. Where a particular case involved circumvention via several countries they are listed separately.

Continue reading “The enforcement of sanctions circumvention in Europe”

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