United Kingdom – Page 8 – European Sanctions Enforcement

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”.

December 1, 2023March 15, 2024 by Mark Handley

UK – HMRC imposes three compound penalties for exports

The UK’s HMRC has today announced three new compound penalties imposed on experts for unlawful exports.

The first penalty was £67,000.31 imposed for the attempted export of goods in breach of the UK’s Russian sanctions. The person or company involved was not named.

The second penalty was for £1,000 and the attempted unlicensed export of dual-use goods. Again the penalised company was not named.

The third penalty was for £9,088.99 for exporting dual-use goods without a licence. This too was anonymised.

November 15, 2023January 11, 2024 by Mark Handley

United Kingdom – law firm fined for sanctions controls

A law firm which self-reported itself to the legal regulator in relation to three real estate transactions has been fined £101,357 by the Solicitors Regulation Authority.

The transactions did not actually involve sanctioned persons or entities, but screening had not been conducted at the time of the transactions and subsequently a possible link between one of the transactions and a designated person was identified.

October 3, 2023March 15, 2024 by Mark Handley

UK’s FCA reported to be investigating firm for sanctions breaches

It has been reported today that the FCA is currently investigating Revolut for permitting transactions valued at £1.7 million in breach of the UK’s sanctions between July and August this year.

Revolut has stated in response that it reported the transactions to the FCA and that the value is £500,000.

September 6, 2023March 15, 2024 by Mark Handley

UK’s FCA publishes review of sanctions compliance

The UK’s financial services regulator has today published a report based on its review of sanctions compliance by a sample of 90 regulated firms.

The FCA emphasised the importance it places on compliance with sanctions and the proactive approach it intends to take to enforcement.

The FCA also published examples of what it considers to be good practice and bad practice. The examples of bad practice include:

(i) insufficient information given to management on sanctions risks, and insufficient management attention;

(ii) global sanctions policies that are insufficiently attuned to the specifics of the UK’s regime;

(iii) over-reliance on third-party screening tools without sufficient oversight or attention to the detail and calibration of such tools;

(iv) insufficient contingency planning in advance of anticipated changes to sanctions;

(v) insufficient resources applied to sanctions compliance resulting in significant backlogs; and

(vi) insufficient and inappropriate calibration of of screening tools allowing either too many false positives, or gaps in screening hits.