The UK’s HMRC has today announced the imposition of compound penalties on four UK exporters. Those companies were not named.
Little information is provided but the exports were all either dual-use goods or military goods.
The compound penalties which were imposed between November and December 2022, were:
The UK’s Financial Conduct Authority has issued a Final Notice to Al Rayan Bank PLC in relation to its failings with customer due diligence, including a lack of due diligence documentation for customers linked to sanctioned countries, or the lack of appropriate enhanced due diligence.
The bank was fined £4,023,600.
The UK’s Financial Conduct Authority has issued a Final Notice against Guaranty Trust Bank (UK) Limited.
The fine was £7,671,800.
The reported failings include a lack of screening against OFSI’s Consolidated List despite policies and procedures requiring such screening. Thousands of accounts had also been established in a way that screening was only done at onboarding and not periodically. Further 90% of resolved sanctions “hits” did not include information or documents demonstrating the basis for the resolution.
The UK’s HMRC has today announced penalties imposed on twelve exporters. The exporters are not named and the details of the offending are limited but the exports all related to either dual-use or military goods.
The penalties imposed were:
The UK’s National Crime Agency has announced the arrest of three individuals on suspicion of various offences including sanctions breaches.
The individuals were not named.
The National Crime Agency has today claimed to have undertaken 100 “disruptions” since the uptick in Russian sanctions following the large-scale invasion of Ukraine.
The NCA stated:
“To date, the NCA has secured nearly 100 disruptions – actions that demonstrably remove or reduce a criminal threat – against Putin-linked elites and their enablers.
These include a number of Account Freezing Orders (AFOs) over accounts held by individuals who are closely linked to sanctioned Russians. The Cell has also investigated and taken discreet action against a significant number of elites who impact directly on the UK, as well as targeting less conventional routes used to disguise movements of significant wealth, such as high value asset sales via auction houses.
Internationally, the NCA’s work has assisted in the freezing of numerous properties, eight yachts and four aircraft, and it continues to work in concert with the Office of Financial Sanctions Implementation to ensure that other assets in the UK are frozen, as well as with global partners to target illicit wealth held abroad”.
Further to our earlier post, the Jersey authorities have admitted that the raids conducted in relation to an investigation involving Roman Abramovich had been conducted unlawfully.
Compensation has also been agreed.
It has been reported today that the UK’s Office of Financial Sanctions Implementation and the English Solicitors Regulation Authority are actively investigating a number of law firms for suspected sanctions breaches.
The law firms were not named.
The UK authorities have arrested a man, Graham Bonham-Carter, as part of an extradition request from the US authorities.
The man is alleged to have conspired to breach US sanctions for and on behalf of Oleg Deripaska.
OFSI today announced that it had imposed a civil penalty for breach of the UK’s Russian sanctions.
The penalty notice is available here.
The fine was imposed on Hong Kong International Wine and Spirits Competition Limited (HKIWS), and was just £30,000.
The conduct in question was the receipt of funds and goods from a designated person. The goods in question were wine bottles. HKIWS was also found to have made “economic resources” available to a designated person. This was in the form of publicity, and illustrates OFSI’s wide view of what amounts to the making available of an economic resource.
