Germany – charges for exporting dual use goods to Russia

Further to our earlier post, the German Federal Prosecutor’s Office has issued a press release stating that charges have now been laid against Vladimir D. for allegedly exporting dual use goods for military use to the Russian military.

The products are said to have been hot isostatic presses, as well as decaboranes, a chemical use in rocket fuel and explosives.

The goods are valued at €1.8m.

Germany – investigation commenced into chemical exports to Syria

After press reports alleging that German company Brenntag AG was involved in the indirect export of chemicals to Syria potentially in breach of the EU’s sanctions, prosecutors in Essen, where Brenntag AG is located, have confirmed that they have initiated legal proceedings and are probing whether to open a formal investigation.

Three NGOs have already filed criminal charges over the chemical exports, including the Berlin-based Syrian Archive, the Switzerland-based organization Trial International, and the New York-based Open Society Justice Initiative.

UK – FCA imposes fine of £102m

The UK’s Financial Conduct Authority has issued a Decision Notice against Standard Chartered Bank including a fine of £102,163,200.

The fine related to KYC failings in general, with a focus on failure to conduct customer due diligence even in situations where sanctions red flags were evident. The FCA noted a lack of financial crime risk, and concerns as to the quality of the advice being given.

A particular focus were the UAE branches of the bank, and also export financing in relation to the export of military goods.

Netherlands – two companies and three individuals convicted of Iran exports

The Dutch District Court in Limburg has convicted two companies and three individuals of unlicensed exports of gas turbine machinery to Iran.

The companies were Euroturbine BV, and its Bahraini subsidiary, and they were fined €500,000 and €350,000 respectively.

The exports were routed via indirect channels to to and mask the destination.

The individuals were respectively sentenced to 12 months in jail, of which 11 months were suspended and 240 hours of community service; 8 months in jail, of which 7 months were suspended and a community service of 200 hours. The third individual , a company employee, was sentenced to 180 hours of community service.

A fourth individual had earlier pled guilty and been sentenced to 120 hours of community service.

Belgium – convictions for breaching Syrian sanctions

It was reported today that the Penal Court of Antwerp has convicted three Belgian  companies and associated individuals of breaching the EU’s Syrian sanctions by exporting 168 tons of isopropranol which is a dual-use product.

AAE Chemie Trading was conditionally fined €346,443 with €50,000 effective. Anex Customs was fined €500,000 of which €100,000 is effective and Danmar Logistics were fined between €75,000 of which €50,000 is effective

Rolf Rippen, the manager of AAE Chemie Trading was sentenced to four months in jail suspended, while Herman Van Landeghem, a manager of Anex Customs and Danmar Logistics, received a 12-month custodial sentence.

Germany – arrest of Russian national for alleged export of military goods to Russia

The German Federal Prosecutor’s Office has issued a press release regarding the arrest of an individual (Vladimir D.) on suspicion of exporting dual-use goods to Russia in breach of EU sanctions.

The goods are valued at €1.7 million and were said to have been exported in two consignments in 2014 and 2018.

As stated in the press release: “In order to circumvent the export controls, the accused is said to have carried out his transactions via changing fictitious recipients, presented false documents and carried out technical manipulations on the goods”.

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The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

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