United Kingdom – Page 7 – European Sanctions Enforcement

May 19, 2022March 15, 2024 by Mark Handley

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.

April 3, 2022January 11, 2024 by Mark Handley

Jersey – authorities conduct raids on premises related to oligarch

It has been reported that the authorities in Jersey have conducted raids as part of an investigation relating to Roman Abramovich.

As part of the investigation it is also being reported that £7 billion in assets have been frozen.

January 10, 2022March 15, 2024 by Mark Handley

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.

Continue reading “UK’s HMRC imposes 10 fines for export control violations”

June 25, 2021March 15, 2024 by Mark Handley

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.

June 25, 2021March 15, 2024 by Mark Handley

UK – OFSI imposes civil penalty for sanctions breaches

Today OFSI announced it had imposed a £50,000 financial penalty on TransferGo in the latest example of the use of its civil enforcement powers.

OFSI’s penalty notice is available here.

The fine was imposed in relation to 16 transactions over nearly 2 years valued at just £7,674.77 through which funds were made available Russian National Commercial Bank, which is a designated person under the EU’s Russian sanctions.

TransferGo did not self report but did cooperate with the investigation.

OFSI’s notice makes clear that the RNCB was not the intended beneficiary of the transactions, rather the recipients of the transfers were accounts held by non-designated persons with RNCB. OFSI has made clear that as funds held in bank accounts are legally held by the banks, that these transfers all amounted to making funds available to RNCB

March 30, 2021March 15, 2024 by Mark Handley

UK – OFSI Annual Report for 2020-2021: enforcement statistics

The UK’s OFSI has published its Annual Report for 2020-2021.

OFSI notes that it received 132 reports of potential financial sanctions breaches.

Interestingly, OFSI declined to publish the usual annual figure of the value of the reported breaches noting that “the total value of potential breaches reported during a financial year can be disproportionately affected by a small number of transactions with a large value”.

November 24, 2020March 15, 2024 by Mark Handley

UK: HMRC fines 19 companies for export controls violations

Today the UK government announced compound penalties of £700,386.01 imposed for breaches of the UK’s export controls.

The announcement from the Export Control Joint Unit provides little detail, but there were 19 settlements in all with the individual penalties ranging from £1,000 to £211,250.

The exports were of dual-use goods and military goods.

This announcement is in line with the HMRC’s policy of entering into civil settlements using its compounding powers, and with anonymised publication of the details.

June 17, 2020March 15, 2024 by Mark Handley

UK: FCA imposes fine including sanctions compliance

Today, the UK’s Financial Conduct Authority imposed a fine of £38,805,400 on Commerzbank.

The Penalty Notice can be found here.

The penalty reflected a 30% reduction from £54,007,800 to reflect cooperation by the bank.

The fine related to failings identified by the FCA in AML and sanctions screening and compliance.

March 30, 2020March 15, 2024 by Mark Handley

UK – OFSI Annual Report: enforcement statistics

OFSI has published its Annual Report for 2019-2020.

In its OFSI notes that it received 1490 reports of suspected sanctions breaches with a total value of £982.34 million.

OFSI also noted that breaches of Libyan sanctions were more prevalent than others.

February 18, 2020March 15, 2024 by Mark Handley

UK: OFSI imposes £20.4m civil penalty

Today the UK’s Office of Financial Sanctions Implementation imposed a civil penalty of £20,471,809.83 on Standard Chartered Bank in the latest (and largest) use of its civil enforcement powers. The fine included a 30% reduction to take account of self-reporting and cooperation.

OFSI’s Penalty Report can be found here.

The breaches of the EU’s Russian sanctions regulation 833/2014 arose out of the provision of multiple loans to the non-EU subsidiary of a Russian bank in breach of the restrictions on certain Russian banks accessing the EU’s capital markets. In total 21 loans valued at over £97m were issued during the period after OFSI acquired its civil enforcement powers.

Initially OFSI’s fines were £31.5m, but the fines were reduced after Standard Chartered exercised its right to a ministerial review of the penalties.