The Dutch authorities have announced the criminal seizure of €137 million suspected of being related to breaches of the Dutch Sanctions Act by a legal entity owned or controlled by a person recently added to the EU’s list of designated persons.
Germany – investigation into purported share transfer
The travel company Tui has confirmed that the German authorities are investigating the circumstances behind the alleged transfer of a 34% stake in the company from Alexi Mordashov, now a designated person under the EU’s Russian sanctions, to his wife.
The allegation is that the transfer would be a breach of the asset freeze imposed upon Mordashov.
Germany – investigation confirmed into engineering company’s Russian exports
The German Ministry of Economy has launched an investigation into whether engineering company Bosch has made unlawful exports to Russian in breach of EU sanctions.
Romania – commencement of investigations confirmed
It has been reported that the Romanian Tax Office (ANAF) has confirmed that it has a number of ongoing investigations into possible breaches of the EU’s Russian sanctions.
No further details were reported.
France – seizure of vessel alleged to be owned by sanctioned Russian bank
The French authorities have seized the cargo ship, Baltic Leader, claimed to be owned by sanctioned Russian bank Promsvyazbank.
The vessel was headed to Russian but seized in the channel.
Germany – charges for dual-use exports to Russia
Further to our earlier post, the Federal Prosecutor’s Office has issued a press release confirming the indictment of Alexander S. on further charges relating to the export of dual-use goods to Russia in breach of EU sanctions.
The value of the exports is estimated at over €1 million.
The press release documents warning issued to Alexander S by the German authorities and his efforts to circumvent the prohibitions through falsifying documents and arranging for export from an Asian country.
Latvia – fines of €3.1m for breaches of Russian sanctions
Following raids in Riga and Tallinn by the Latvian Security Police, in close cooperation with the Estonian Internal Security Service (ISS), it was reported today that two individuals have been fined by the Latvian courts for breaching the EU’s Russian sanctions.
The breaches involved making funds available, through contracts involving broadcasting, to a designated person. The individuals (Oleg Solodov and Margus Merima) were each fined €25,000, and a further €3 million was confiscated.
Germany – five being investigated in relation to export of gas turbines to Crimea
It is being reported today that the Hamburg Public Prosecutor’s Office is currently investigating five individuals in relation to the export from Germany to Crimea of gas turbines manufactured by Siemens.
The broader investigation into the export of these turbines has been ongoing since 2018. See our earlier post.
Four of the individuals being investigated are German nationals, three of whom worked for Siemens in Russia, and the fifth is a Swiss national.
UK: OFSI’s second penalty for the day – Russian sanctions
OFSI has today issued a second penalty for breach of the EU’s Russian sanctions, again using its civil enforcement powers.
The penalty notice is available here.
The penalty, of £36,393.45, was imposed on Clear Junction Limited. The transactions in this case are the same as those relating to TransferGo, although OFSI makes clear that it was Clear Junction which reported the transactions. It is noteworthy that some of the impugned transactions took place after the first report to OFSI.
OFSI’s notice also makes the point that the breach here was of the EU’s Russian sanctions, and that post-Brexit OFSI will continue to investigate breaches of the EU’s regulations that may have taken place before Brexit.
UK – OFSI imposes civil penalty for sanctions breaches
Today OFSI announced it had imposed a £50,000 financial penalty on TransferGo in the latest example of the use of its civil enforcement powers.
OFSI’s penalty notice is available here.
The fine was imposed in relation to 16 transactions over nearly 2 years valued at just £7,674.77 through which funds were made available Russian National Commercial Bank, which is a designated person under the EU’s Russian sanctions.
TransferGo did not self report but did cooperate with the investigation.
OFSI’s notice makes clear that the RNCB was not the intended beneficiary of the transactions, rather the recipients of the transfers were accounts held by non-designated persons with RNCB. OFSI has made clear that as funds held in bank accounts are legally held by the banks, that these transfers all amounted to making funds available to RNCB