It was reported today by Reuters that there are 150 ongoing sanctions investigations being undertaken in Germany.
No further details were published.
Latvian enforcement: 14 ongoing criminal prosecutions
In response to questions about Russian sanctions enforcement the Latvian authorities have confirmed that they have 14 ongoing criminal prosecutions of which three relate to exports, including circumvention of sanctions by routing exports through China and central Asia, and the others to breaches of financial sanctions.
The Latvian authorities also stated they received 281 suspicious activity reports during 2022 in relation to Russian sanctions, and had received 309 so far in 2023.
Finland investigates logistics operator
It was reported today that the Finnish Central Criminal Police are investigating a Finnish company for exports to Russia in breach of the EU’s sanctions.
The investigation was commenced in 2019, with the offences alleged to have taken place between 2016 and 2020.
The exports were of technology destined for use by arms manufacturers in Russia. It is also alleged that the Finnish company was controlled, albeit not owned, by a designated person under the EU’s Russian sanctions.
UK’s OFSI enforces and gives Wise words of compliance advice
The UK’s Office of Financial Sanctions Implementation (OFSI) has announced its most recent enforcement action, coupled with changes to its Guidance on its attitude to enforcement.
On 29 June 2022 a new person was added to the UK’s sanctions list as a “Designated Person”. At 4am the next morning a debit card in that Designated Person’s name, but relating to a separate company (albeit one owned or controlled by the Designated Person) was used to withdraw £250. OFSI’s published action relates to Wise Payments Limited (Wise), the regulated financial services firm with which the account was held. While Wise had reacted to the designation of its customer by blocking transfers into or out of the account, its policy was not to stop debit cards on the basis that it often had a lot of false positives with sanctions screening and that it had a duty to its customers as well. The debit card was not blocked until the after the weekend as its sanctions team did not work on the weekend. No further withdrawals were made over this period.
OFSI’s view in its notice is that blocking debit cards while ascertaining if a screening match is genuine is a wholly proportionate policy for managing sanctions risk. Further, not having a sanctions team to review screening hits over the weekend was insufficient.
Thus while the value of the breach was low, and Wise self-reported promptly and co-operated, OFSI applied its “severity” test and determined that Wise’s actions amounted to a moderately severe breach. It was on this basis that OFSI has published the details of this breach, albeit it did not impose a civil penalty nor propose a criminal prosecution. This is the first time that OFSI has used its new “disclosure” power in this way.
The other noteworthy factor is that Wise’s conduct was treated as “making available” assets to a designated person. Wise’s role was passive – it took no step to transfer or give assets to the Designated Person. Nonetheless, the failure to block the debit card was interpreted as itself amounting to “making available” what should be frozen assets to a designated person. This is helpful in clarifying the breadth of the view taken by OFSI on what can amount to “making available”.
Germany – conviction for exporting drone parts to Russia
It is being reported (behind a paywall) that an individual has been convicted by the Koblenz Regional Court for exporting engines for the “Altius” drones to Russia in breach of EU sanctions.
The 62-year old unidentified individual was sentenced to 5 years in prison.
Czechia – investigation launched into Austrian bank for suspected Russian sanctions breaches
The National Anti-Terrorism Centre of Czechia has initiated an investigation into the activities of the Austrian Raiffeisen Bank International due to its subsidiary’s operations in Russia.
An earlier complaint against Raiffeisen Bank had been filed by the Association for Citizens’ and Entrepreneurs’ Rights.
Police have confirmed that the Anti-Terrorism Centre is conducting an investigation regarding the banking group. However, no further details were disclosed.
Arrest in Germany for exporting dual-use goods to Russia
It has been reported today that the German authorities have arrested a German national on suspicion of exporting dual-use goods to Russia.
The goods were being exported to a Russian arms manufacturer via either Switzerland or Lithuania, and were valued at over 2 million euros, and were being used to manufacture sniper rifles.
The suspect, named as Ulli S, was first arrested in France and then extradited to Germany under a European arrest warrant.
UK imposes £1m fine for exports to Russia
The British authorities today announced the imposition by HM Revenue and Customs of a £1m compound penalty on an unnamed UK company for unlicensed exports to Russia in breach of the UK’s Russian sanctions regulations.
No further information has been released.
Ireland – investigation into drone parts and possible trade sanctions breach
It has been reported today that the Department of Enterprise, Trade and Employment is investigating potential breaches of sanctions, after a “Made in Ireland” tag was found on components within drones used by Russia in Ukraine.
Netherlands – man arrested on suspicion of breaching Russian trade sanctions
The Dutch authorities have announced the arrest of a 41-year old man on suspicion of exporting microchips indirectly to Russia through third countries in circumvention of the EU’s sanctions.
The products are computer parts and were exported through third countries such as Kazakhstan, Kyrgyzstan, Mongolia, Uzbekistan, Turkey and the UAE.
Residential and business premises were searched in Moerdijk as part of the investigation.