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.

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.

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.

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.

 

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”

UK – FCA investigating banks over Iran sanctions allegations

Following widespread press reports (initially in the Financial Times) that a series of front companies linked to the Iranian Revolutionary Guard held accounts in the UK with Lloyds Bank and Santander, it is now being reported (behind a paywall) that both banks have been contacted by the Financial Conduct Authority in relation to the allegations.

Both banks have denied breaching sanctions.

Germany: BaFin investigating German bank over Iran sanctions

The German financial services regulator, BaFin, has issued a press release confirming an investigation into the money laundering and sanctions compliance of the bank Varengold Bank AG. The particular focus is Iran sanctions.

BaFin has prohibited the bank from processing payment transactions involving Iran, or person or companies resident in Iran. BaFin has also appointed a representative to oversee compliance with this prohibition.

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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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