UK – investigation into possible sanctions offences by Petr Aven

It has been reported today that the UK’s National Crime Agency is investigating  possible sanctions breaches by six companies and individuals associated with Petr Aven who is a designated person under the UK’s sanctions.

The authorities have obtained Account Freezing Orders over two accounts allegedly holding £1.5 million and these orders are being challenged by Mr Aven.

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.

UK’s HMRC imposes 10 fines for export control violations

The UK’s HM Revenue and Customs has today announced the imposition of 10 compound penalties in relation to failures to comply with the UK’s export control regulations for dual-use and military goods. The fines were imposed between March and November 2021.

HMRC’s Notice to Exporters can be found here.

In line with HMRC’s standard practice the compound penalties are anonymised and of low value, with little information made available. The information provided is supplied below.

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UK: OFSI’s second penalty for the day – Russian sanctions

OFSI has today issued a second penalty for breach of the EU’s Russian sanctions, again using its civil enforcement powers.

The penalty notice is available here.

The penalty, of £36,393.45, was imposed on Clear Junction Limited. The transactions in this case are the same as those relating to TransferGo, although OFSI makes clear that it was Clear Junction which reported the transactions. It is noteworthy that some of the impugned transactions took place after the first report to OFSI.

OFSI’s notice also makes the point that the breach here was of the EU’s Russian sanctions, and that post-Brexit OFSI will continue to investigate breaches of the EU’s regulations that may have taken place before Brexit.

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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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