United Kingdom – Page 3 – European Sanctions Enforcement

April 22, 2024 by Mark Handley

UK – Charity Commission investigates sanctioned person’s fundraising

The UK’s Charity Commission has issued a press release stating that it had launched a statutory investigation into the activities of Aozma Sultana who is designated under the UK’s terrorism sanctions.

The Charity Commission has confirmed that Aozma Sultana, by virtue of being a designated person, and so subject to an asset freeze, has been removed from any trustee or senior management role in the charity Gaza Now.

The Commission is also investigating the role of two companies, Aakhirah Limited and Al-Qureshi Executives is possible misappropriation of funds by the charity.

This is not the first action taken by the Charity Commission in relation to sanctioned trustee. In December 2023, it issued a press release in relation to action taken against Dr Viatcheslav Kantor who is designated under the UK’s Russian sanctions.

April 19, 2024 by Mark Handley

UK – Government Minister gives timelines for first post-2022 financial sanctions fines

The Parliamentary website has today published a letter from Minister Anne Marie Trevelyan MP to the Chair of the Foreign Relations Committee which includes a section on the current state of UK sanctions enforcement. The letter is part of a report by the Committee.

In relation to sanctions enforcement the letter indicates that the first fines for breaches of sanctions imposed since 2022 are expected this year.

The section of the letter can be quoted in full below:

“Fines for non-compliance

Secondly, regarding the number of fines that have been issued for non-compliance with our Russia sanctions regime, I can confirm that there have been 10 Monetary Penalties imposed by OFSI since it received the power to impose these in 2017, totalling £22m.

OFSI cannot pre-determine case outcomes but does expect to see the first Monetary Penalties resulting from 2022 Russia designations come to fruition in 2024. This is in line with other jurisdictions, including the US, given the time it takes to properly investigate cases.

Financial sanctions breaches are often complex and investigations proportionately long. OFSI is responsible for both investigating breaches and deciding on the appropriate outcome, including initial penalty amounts. There are several important statutory periods to allow for representations and appeals that OFSI must comply with that also impact the time between investigations commencing and penalties being made public.

Some breaches are found to be relatively minor in nature. In these cases, OFSI will not necessarily impose a penalty, as it may be more appropriate to deal with the case in a different way such as a warning letter or referring the matter to a regulator. In 2022-2023, OFSI recorded 473 suspected breaches of financial sanctions (excluding oil price cap and counter-terrorism breaches). This is a significant increase on the 147 cases recorded in 2021-2022. This increase was expected given the scale of increased Russia sanctions, and OFSI has increased its enforcement capacity in response.”

April 9, 2024 by Mark Handley

United Kingdom – charges to two further individuals added to existing prosecution

Further to our earlier post, regarding the UK’s National Crime Agency charging Dmitry Ovsyannikov with multiple counts of breaching the UK’s Russian sanctions, following a hearing in London it is now apparent that the National Crime Agency has also charged Ekaterina Ovsiannikova (the first defendant’s wife) and Alexei Owsjanikow, (the second defendant’s brother).

As per Spotlight on Corruption, a further hearing is listed for 28 June to hear application by the defendants to dismiss the charges.

The hearing, as reported by Global Investigations Review (behind a paywall), on Monday was largely procedural and dealt with issues like bail terms. The defendants have yet to enter a plea.

April 4, 2024 by Mark Handley

United Kingdom – Gambling Commission fines two operators citing sanctions compliance failings

The UK’s regulator for the gambling sector, the Gambling Commission has issued a press release recording fines of £343,035 against Hillside (UK) Gaming ENC and £239,085 against Hillside (UK Sports) ENC.

Both companies operate under the Bet365 brand.

The fines in part relate to social responsibility failings, and partly to financial crime compliance failings including “failing to undertake financial sanctions checks on new customers prior to their first deposits”.

March 29, 2024 by Mark Handley

United Kingdom – joint sanctions investigation with US into $20 billion crypto transactions

It is being reported that the UK and the US are undertaking a joint investigation into $20 billion in crypto currency transactions said to be in breach of Russian sanctions.

The payments under scrutiny flowed through the Moscow-based Garantex crypto exchange, utilizing the dollar-pegged stablecoin Tether.

The original story was published by Bloomberg, behind a paywall.

It is also being reported that the National Crime Agency and HM Treasury have provided no comment in relation to the investigation.

March 15, 2024March 15, 2024 by Mark Handley

European sanctions enforcement: the last two months

This blog has been live now for just over two months.

During that time and by way of recap, a number of states have provided updated enforcement statistics in that period (Finland, Switzerland, Latvia), but the period has also seen a significant volume of new enforcement activity:

Continue reading “European sanctions enforcement: the last two months”

February 7, 2024March 15, 2024 by Mark Handley

UK – FCA investigating banks over Iran sanctions allegations

Following widespread press reports (initially in the Financial Times) that a series of front companies linked to the Iranian Revolutionary Guard held accounts in the UK with Lloyds Bank and Santander, it is now being reported (behind a paywall) that both banks have been contacted by the Financial Conduct Authority in relation to the allegations.

Both banks have denied breaching sanctions.

February 1, 2024February 1, 2024 by Mark Handley

United Kingdom – NCA charges Russian national with seven counts of circumventing sanctions

It has been reported today that the UK’s National Crime Agency has arrested and charged Dmitry Ovsyannikov, a Russian national, with seven counts of circumventing sanctions as well as two money laundering charges.

Ovsyannikov was formerly the governor of Russian-seized Sevastopol and was designated by the EU in 2017 and then post-Brexit by the UK in 2020.

He is due to first appear in Southwark Crown Court on 20 February. He was arrested on 22 January.

To date the National Crime Agency has not issued a press release

January 22, 2024January 22, 2024 by Mark Handley

UK reports Russia to UN North Korean sanctions committee

It has been reported today that the UK has provided the UN Committee responsible for oversight of the UN’s sanctions against North Korea with a dossier of evidence said to establish breaches of those sanctions by Russian shipping.

The Committee has the power to designate vessels which it finds were complicit in breaching the existing sanctions.

December 12, 2023March 15, 2024 by Mark Handley

UK – OFSI’s enforcement statistics for 2022-23

The UK’s Office of Financial Sanctions Implementation has today published its Annual Review for 2022-2023.

The report includes the following regarding enforcement activity:

“As of April 2023, OFSI’s Enforcement Unit had 172 cases under live investigation, many of which are complex and remain ongoing.

In 2022-2023, OFSI recorded 473 suspected breaches of financial sanctions (excluding oil price cap and counter-terrorism breaches). This is a significant increase on the 147 cases recorded in 2021-2022. This increase was expected given the scale of increased Russia sanctions, and OFSI’s increased enforcement capabilities. This data refers to the year in which a suspected breach is recorded, rather than the year in which the potential breach activity occurred. Recorded breaches includes cases which are self-reported, reported by a third party, and those independently generated by OFSI.

Over the course of the financial year, OFSI issued 7 warning letters in response to confirmed breaches which OFSI did not consider warranted public enforcement action, and 2 monetary penalties. 51 cases were closed with no further action, 44 of which related to Russia related sanctions breach reports. OFSI does not in all cases provide its view of whether a breach occurred or not, although many suspected breaches recorded by OFSI are considered not to be breaches of financial sanctions following further investigation. A number of cases in this period were referred to other agencies, including criminal and regulatory authorities. OFSI does not provide further breakdowns on referrals to criminal authorities”.