Syria – European Sanctions Enforcement

July 2, 2025July 2, 2025 by Mark Handley

Spain – sanctions-related investigation into origins of imported diesel

It has been reported that the Spanish National Anti-Fraud Investigation Office, and competition authorities, have opened an investigation into the importation of diesel to Spain from Turkey and Morocco.

The suspicion being investigated is whether the diesel actually originates from Syria, Russia and/or Iran.

The investigation is reported to have been commenced in late 2024.

As further reported: “Several of the companies that were accused of bringing oil from Morocco due to their price advantage as they are of Russian origin in 2023 have either been disqualified or are currently involved in legal proceedings for fraud“.

June 30, 2025June 30, 2025 by Mark Handley

United Kingdom – prosecution for exports of military goods to Iran, Libya, South Sudan, Sudan and Syria

As first reported by Global Investigations Review (behind a paywall), the UK is prosecuting two individuals for the suspected export of military goods to a range of countries including Iran, Libya, South Sudan, Sudan and Syria.

The defendants David Greenhalgh, 67, and Christos Farmakis, 47, pled not guilty to 17 charges at Southwark Crown Crown on 13 June.

The exports are said to have taken place between 2009 and 2016, with the prosecution underscoring the absence of limitation periods in the UK.

As stated by GIR:

“The defendants allegedly helped ship fighter jets, radar systems, missiles and ammunition to Libya; “battle tanks and associated spare parts”, AK-47 rifles, anti-tank missiles and ammunition to South Sudan; missiles, launchers and rocket-propelled grenades to Syria; and Pechora S-125 surface-to-air missile systems, radar equipment and MiG-29, Su-25 and Su-27 fighter jets to Sudan. …

Farmakis is further accused of being involved in the illicit supply of 5,500 AK-47 rifles and 100,000 tonnes of ammunition to Syria, as well as 25,000 pistols to an unnamed country and unspecified quantities of AK-47 rifles to South Sudan and Iran.

Greenhalgh is separately accused of helping to export Mi-24V attack helicopters to Sudan”.

Trial has been set for April 2026.

February 13, 2024 by Mark Handley

France – Anti-Terrorism Prosecutor advances sanctions charges against Lafarge and individuals

On Friday France’s National Anti-Terrorism Prosecutor’s Office applied to the Paris court to have charges of terrorist financing, and breach of the relevant EU sanctions heard against Lafarge Holcim and nine individuals.

This criminal trial would go ahead before the trial of Lafarge on allegations of crimes against humanity after the Court of Cassation ruled last month that those charges should proceed.

For our earlier posts on the Lafarge matter see here.

June 26, 2023February 13, 2024 by Mark Handley

France – some charges against Lafarge-Holcim dropped

Further to our earlier posts (here, here, and here) regarding an investigation into whether cement company Lafarge-Holcim breached EU sanctions by making payments to designated persons, it has been announced that the charges relating to financing of terrorism breaches are being discontinued.

The charges relating to crimes against humanity continue.

In October 2022 Lafarge-Holcim had plead guilty to related charges before the US Department of Justice and agreed to pay $778 million.

April 4, 2023January 11, 2024 by Mark Handley

Netherlands – fine imposed by regulator (largely) upheld

An unnamed financial services provider had appealed three fines imposed on it by the Dutch National Bank in relation to inadequate AML and sanctions screening in relation to transactions to do with Somalia, Syria and Saudi Arabia.

The fines were €8,000, €5,000 and €10,000 for the three identified breaches.

The fine of €8,000 was reduced on appeal to €7,600 on the basis of delay by the regulator, but the others were upheld.

August 31, 2022January 11, 2024 by Mark Handley

Netherlands – 30 month custodial sentence for breach of ISIS sanctions

The Rotterdam District Court has imposed a 30-month custodial sentence on an individual relating to a two-year period in which financial transfers of approximately $140,000 were made in breach of EU sanctions against ISIS and Al Qaeda.

The transfers were related to efforts to smuggle Dutch women who had travelled to Syria and Iraq to be part of ISIS out of that region and back to the Netherlands.

May 19, 2022March 15, 2024 by Mark Handley

UK’s OFSI imposes fine for breach of Syrian sanctions

OFSI has today announced a civil penalty of £15,000 against Tracerco Limited for a breach of the EU’s Syrian sanctions.

OFSI’s Penalty Notice is available here.

The breaches related to airline tickets valued at £2,956.43 purchased for a Tracerco employee through a travel agency. The airline in question, however, was Syrian Arab Airlines which is designated under the EU’s sanctions.

OFSI, therefore, concluded that purchasing the tickets amounted to making funds available to a designated person. OFSI also commented, in relation to the requirement that it showed Tracerco either knew or had reasonable grounds to suspect that the transactions would breach the regulations, that operating in the region was sufficient to satisfy this requirement.

December 14, 2021January 11, 2024 by Mark Handley

Denmark – sentences and fines for breach of Syrian sanctions

Two Danish companies have been convicted of exporting 177,000 tonnes of jet fuel to Syria in breach of the EU’s sanctions.

In total some 33 transactions took place between 2015 and 2017, with the exports routed through Russian companies bound for Syria.

The company Dan-Bunkering was fined DKK 30 million ($4.6m), with a further DKK 15 million of unlawful profits confiscated.

The parent company Bunker Holding was fined DKK 4 million.

The Dan Bunkering CEO was also convicted and given a four-month custodial sentence , suspended pending a one year probation period.

October 14, 2021January 11, 2024 by Mark Handley

Netherlands – conviction for exports to Syria

The Rotterdam District Court has convicted a manager of a wholesale business of exports to Syria in breach of EU sanctions.

The export was of 128,000 litres of acetone, which is a product listed in Annex IX of the EU regulation.

The sentence was for a three month sentence suspended for 2 years and 180 hours of community service. This was lower than sought by the prosecution.

The company responsible for the exports was acquitted on the basis that the prosecution only commenced after it had already been wound up.

November 12, 2020January 11, 2024 by Mark Handley

Denmark – charges for breach of Syrian sanctions

Denmark’s financial crimes unit on Wednesday announced charges against a Danish company suspected of violating EU sanctions on Syria by delivering large quantities of fuel to Russian warplanes there.

The 33 transactions, involving 172,000 tonnes of kerosene, carried out between 2015 and 2017, amounted to 647 million kroner (87 million euros, $102 million), according to the Danish State Prosecutor.

Danish media has reported the company as Dan-Bunkering. A holding company and the director of one of the companies involved are also being prosecuted.