Iran – European Sanctions Enforcement

April 29, 2024April 29, 2024 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”

March 15, 2024March 15, 2024 by Mark Handley

European sanctions enforcement: the last two months

This blog has been live now for just over two months.

During that time and by way of recap, a number of states have provided updated enforcement statistics in that period (Finland, Switzerland, Latvia), but the period has also seen a significant volume of new enforcement activity:

Continue reading “European sanctions enforcement: the last two months”

February 9, 2024 by Mark Handley

Germany: BaFin investigation into bank ongoing

There has been press reporting into the ongoing investigation by the German financial service regulator, BaFin, into the German bank Varengold Bank AG.

The investigation remains ongoing and so far no individuals have been accused of wrongdoing, and no reference has been made in relation to a criminal prosecution.

For our earlier post regarding the BaFin announcement see here.

February 7, 2024March 15, 2024 by Mark Handley

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.

September 23, 2023January 11, 2024 by Mark Handley

German authorities confirm Iran sanctions investigation

It has been reported today that the German authorities have confirmed the commencement of an investigation following press reporting regarding whether German companies which attended a trade fair in Iran had done so in breach of EU sanctions.

August 3, 2023February 9, 2024 by Mark Handley

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.

November 14, 2022January 11, 2024 by Mark Handley

Norway – custodial sentence for breach of Iran sanctions

Further to our earlier post, a former university professor in Norway has been convicted of breaching Norway’s Iran sanctions.

The man has been sentenced to 8 months in jail.

The conviction relates to sharing technology without a licence with Iranians.

September 20, 2022March 6, 2024 by Mark Handley

Germany – man charged for exports to Iran

Further to our earlier post, the German Federal Prosecutor’s Office has issued a press release confirming that Alexander J. has been charged with various breaches of the EU’s sanctions against Iran.

The Iranian company purchasing equipment through Alexander J. is said to be a designated person, while the products themselves are also prohibited from being exported to Iran.

The goods are said to have been for use in Iran’s nuclear and missile programs, and to have been valued at over €1 million.

June 28, 2022January 11, 2024 by Mark Handley

Netherlands – 18 month sentence for exports to Iran

The Dutch Supreme Court has denied an appeal against an 18-month custodial sentence against an individual for his role in seven exports of goods to the National Iranian Gas Company which is a designated person under the EU’s sanctions.

The shipments were made via Turkey or Dubai and the defence argued in the appeal that this was not “indirectly” making economic resources available to a designated person. The Supreme Court disagreed.

June 8, 2022March 15, 2024 by Mark Handley

UK – convicted exporter to Iran ordered to pay £700,000

HMRC has announced that British national Alexander George has been ordered to pay £700,000 in a confiscation order issued by the Southwark Crown Court. The funds are the proceeds of crime related to his conviction for exporting parts for jet fighters to Iran.

For more on his conviction back in 2018 see our earlier post.