United Kingdom – Page 3 – European Sanctions Enforcement

November 4, 2024November 4, 2024 by Mark Handley

United Kingdom – HMRC compound penalties for Russian sanctions and export control violations totaling £1.9m

The UK’s HMRC has issued several “Notices to Exporters” with updates as to recent enforcement activity.

In one Notice, HMRC states that is has agreed three compound penalties with different entities:

“August 2024 – £402,417.75 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008
August 2024 – £37,743.34 was paid relating to the unlicensed exports of dual-use goods controlled by Retained Regulation 428/2009
September 2024 – £1,480,785.44 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008″

As ever with such penalties the nature of the offending is not given, the identity of the offender is not given, and no indication is given as to whether or not the fine includes a confiscation element for the proceeds of the crimes.

In a second Notice, HMRC describes the compound penalty:

“August 2024 – £58,426.45 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019”.

Again, no other details or information is provided, although HMRC notes that this is its 6th compound penalty in relation to Russian sanctions totaling £1,363,129.

October 11, 2024October 11, 2024 by Mark Handley

United Kingdom – 37 ongoing oil price cap investigations

The BBC is reporting the results of a Freedom of Information Act request it has made to OFSI.

The response itself is not currently on the website of either OFSI or HM Treasury.

The BBC is reporting the following statistics:

52 investigations opened since December 2022
15 of those have been concluded with no further action taken; and
37 of the investigations are ongoing.

As per our earlier post, in an earlier Freedom of Information response OFSI confirmed that as of April 2024 it had started 12 investigations of which 9 had been discontinued without action taken.

As such 40 new oil price cap investigations have been started since April 2024.

Since April six investigations have been concluded.

October 2, 2024October 2, 2024 by Mark Handley

UK – FCA fines bank £29m for sanctions compliance failings

The UK’s Financial Conduct Authority has today fined Starling Bank £28,959,426 for sanctions compliance failings.

The Final Notice states that the bank became aware in January 2023 that its screening was being done against a small sub-set of the Consolidated List of sanctions targets.

The FCA described the compliance program at Starling as “shockingly lax”.

The FCA also noted that the fine would have been £40,959,426 without Starling’s agreement to resolve the matter.

September 27, 2024September 27, 2024 by Mark Handley

UK – OFSI imposes £15,000 civil penalty

The UK’s Office of Financial Sanctions Implementation has today issued notice of a civil monetary penalty it has imposed on a company called Integral Concierge Services Limited (“ICSL”).

The penalty was for £15,000.

The fine related to 26 payments made to, or received from, a designated person under the UK’s Russian sanctions. The payments related to property management including collecting rent, paying for maintenance, and ICSL taking its own management fees. The designated person was not named.

The company did not initially self-disclose, but did then cooperate including by disclosing breaches that had not yet been identified by OFSI.

The company also breaches the reporting requirements under several general licences, but OFSO chose to not fine in relation to those breaches but rather to treat those failures as aggravating factors.

September 11, 2024 by Mark Handley

UK – HMRC fines two companies for export control breaches

The UK’s primary export controls enforcement body, HMRC, has today issued a Notice to Exporters giving some details on two compound settlements reached with two UK companies.

The first was reached in April 2024 and the unnamed company agreed to pay £258,000 in relation to the “unlicensed transfer of dual-use goods controlled by Retained Regulation 428/2009”.

The second was reached in June 2024 and the unnamed company agreed to pay £90,853.20 in relation to the “the unlicensed exports of military goods controlled by The Export Control Order 2008”.

No other information has been made available.

August 23, 2024 by Mark Handley

United Kingdom – 12 oil price cap investigations by OFSI

It is being reported (here albeit behind a paywall), that as of April 2024 the UK’s Office of Financial Sanctions Implementation (OFSI) had twelve ongoing investigations relating to possible breaches of the oil price cap imposed as part of the UK’s sanctions against Russia.

The information comes from a Freedom of Information Act request made by the publication Trade Winds. The response is not available on OFSI’s website.

OFSI is also reported to have confirmed that 9 of the twelve investigations were discontinued in April 2024 with no further action taken.

No information was provided on the current status of the other three investigations that were live in April, or whether any further investigations have been commenced since April.

As noted in our previous post from May, at that stage HM Treasury had stated that it “a number of investigations” then ongoing into alleged oil price cap breaches.

July 31, 2024 by Mark Handley

UK – investigation by HMRC into potential Airbus violations of export controls

Reuters has reported that Airbus’s most recent half-yearly financial statements include reference to an ongoing investigation by HMRC.

Under the heading “HMRC Export Control Investigation”, the financial company records: “Airbus is fully cooperating with an investigation by the Revenue and Customs Authority of the United Kingdom into possible violations of the United Kingdom’s export control rules. It is not expected that the resolution of this matter will have a material financial impact“.

No further details are provided.

July 29, 2024August 1, 2024 by Mark Handley

UK – confiscation of more than £750,000 from family and estate of Petr Aven

It is being reported that the UK’s National Crime Agency has completed the confiscation of funds related to Petr Aven.

The sum of £750,000 was confiscated from bank accounts held in the name of Petr Aven’s wife and others.

A sum of cash initially recovered by the NCA from a residence outside London was also confiscated.

The funds were confiscated under the Proceeds of Crime Act 2002.

Updated on 1 August to reflect issuance of NCA’s press release:

The NCA has stated that the funds, totalling £783,827.34 were held for the benefit of Petr Aven although not in his name, and that the breaches of sanctions giving rise to the funds being the proceeds of crime were: “Attempts to relocate the funds, as well as transactions made after March 15 2022 by Aven’s estate manager, Stephen Gater … . These included the payment of salaries to over 20 members of Aven’s household staff, and the sale of a Bentley Bentayga worth £160,000“.

July 23, 2024August 1, 2024 by Mark Handley

UK – extradition to the US for person suspected of Iran sanctions breaches

A press release from the US Department of Justice records that an individual, Saeid Haji Agha Mousaei, was arrested in the UK on 24 January 2023 pursuant to an Interpol diffusion notice.

Mr Mousaei was then subsequently extradited to the US where he faces multiple charges arising from the alleged supply of “controlled electronics with military applications, including signals equipment like oscilloscopes and spectrum analyzers, for export and re-export to Iran”.

It is alleged that false documentation was prepared which indicated that the goods were to remain in countries such as the UAE and Armenia, but the goods were all transshipped to Iran via the UAE.

July 23, 2024January 15, 2025 by Mark Handley

UK – two law firms reported to OFSI by legal regulator

It is being reported that two law firms have been reported by the Solicitors Regulation Authority (SRA) to the UK’s OFSI.

It is alleged that the law firms were facilitating financial transactions valued at more than £300,000. It is unclear whether the conduct relates to designated persons, trade sanctions, or the UK’s prohibitions on Russian investment.

The attention on law firms chimes with the report yesterday that there has been an investigation in Germany relating to a potential breach of the EU’s prohibitions on legal advice.