Netherlands – Page 3 – European Sanctions Enforcement

January 23, 2024January 25, 2024 by Mark Handley

Netherlands – three arrested on suspicion of circumventing Russian sanctions

The Dutch FIOD has today announced three arrests as part of an ongoing criminal investigation into suspected exports in circumvention of the EU’s trade sanctions against Russia.

The individuals are two men from Diemen and a woman from The Hague. The men were both directors of a company founded in 2017, and the arrested woman was an employee.

UPDATE: it is now being reported that the Dutch company involved is ETW-Tekhnologiya and that the company’s founder, Mikhail Volovik, is being sought but has not yet been arrested

The goods are described as technological and laboratory goods capable of military use – i.e. dual-use goods.

Searches and witness interviews have taken place in the Netherlands, Germany, Latvia, Lithuania and Canada.

January 18, 2024 by Mark Handley

Netherlands – sanctions fines imposed by Dutch National Bank upheld and reduced on appeal

An unnamed financial services provider regulated by the Dutch National Bank has challenged fines imposed upon it in relation to KYC and due diligence failings including in relation to sanctions screening.

The DNB had initially fined the provider €1.1m and €625,000, but these were reduced through a review process to €850,000 and €480,940.

The first fine in particular related to allegations of a failure to screen any of the sample of analysed customers against EU and Dutch sanctions lists.

On further appeal to the Rotterdam District Court the fines were upheld but further reduced to €718,841.25 and €451,250.

December 5, 2023January 11, 2024 by Mark Handley

Netherlands – arrests and raids regarding Russian sanctions

It has been reported today that the Dutch authorities, after a tip-off from unnamed US “agencies” have conducted searches at homes and business addresses in Sluis and Rotterdam.

Related search and arrests took place in the Belgium (see our related post) at the same time, and in total across both countries six have been arrested.

The allegations relate to the export of products and technology to Russia.

November 15, 2023January 23, 2024 by Mark Handley

Netherlands – authorities apply to wind up company fined for sanctions breaches

The Dutch Public Prosecution Service has announced that it is using its civil powers to apply for the dissolution of a company fined for Russian sanctions breaches and the appointment of a independent liquidator to oversee the process.

For our earlier post regarding the corporate fine see here.

November 1, 2023January 11, 2024 by Mark Handley

Netherlands – custodial sentence and corporate fine

Further to our earlier post regarding the sentence sought against Dmitri K, the sentencing has now been handed down. Dmitri was sentenced, in absentia to 18 months’ in jail, and his (unnamed) company was fined €200,000.

The sentence relates to the export of microchips to Russia, with the court finding that Dmitri K was aware that the exports were unlawful.

October 17, 2023January 11, 2024 by Mark Handley

Netherlands – 3 year sentence and fine sought

It was reported today that the Dutch Public Prosecution Service is seeking the conviction of an individual, Dmitri K, for the export of microchips and drones to Russia and for falsifying export documents.

The prosecution is seeking 3 years in jail and a fine of €350,000. The man is being tried in absentia having left Holland and travelled to Russia.

October 13, 2023January 11, 2024 by Mark Handley

Dutch fine four companies for sanctions breaches

The Dutch authorities have today secured settlement against four companies and eight individuals for breaching the EU’s Russian sanctions concerning Crimea through involvement in the export and machinery used in the construction of the Kerch Bridge.

The eight people were sentenced to community service ranging from 20 to 60 hours while the four companies paid fines totalling €160,000, with profits of €71,000 confiscated from one of the companies.

The case was resolved without a trial. The investigation commenced in 2017 after press reporting, and initially involved investigation into the activities of seven companies.

The names of the companies have not been published.

September 26, 2023January 11, 2024 by Mark Handley

Netherlands announce 55 ongoing criminal investigations

The Dutch have announced that the Public Prosecution Service is currently undertaking 55 criminal investigations into suspected breaches of Russian and Belarusian sanctions.

Little information on the breaches is available, but the authorities have stated that roughly two thirds relate to breaches of trade sanctions, and one third to financial sanctions.

As of December the number was at 27, meaning 28 have been added during 2023 to date.

September 15, 2023January 11, 2024 by Mark Handley

Netherlands: two arrested including Ministry of Defence official for sanctions offences

The Dutch Fiscal Information and Investigation Service has announced the arrest of an employee of the Ministry of Defence on suspicion of exporting aircraft spare parts through various companies and countries to Russian in breach of the EU’s sanctions.

The announcement confirms that this is the second arrest in the same investigation with an earlier arrest and raid conducted on 29 August 2023.

August 10, 2023January 11, 2024 by Mark Handley

Netherlands – National Bank critical of de Volksbank sanctions compliance

The annual report for de Volksbank N.V. has revealed the results of a sanctions-review by the Dutch National Bank.

The report states:

“Furthermore, de Volksbank has initiated a comprehensive remediation project to enhance the customer screening and transaction screening systems. This project will remediate findings from regulatory testing of our screening systems conducted by DNB in the second half of 2022, and is expected to be finalised in the first half of 2024”.

The report also notes that the DNB had identified compliance failings in the AML and anti-terrorist financing space, and de Volksbank has made a provision of €1 million in anticipation of the expected fine.