United Kingdom – Page 9 – European Sanctions Enforcement

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.

February 4, 2020January 11, 2024 by Mark Handley

UK – bank investigated for alleged Iran sanctions breaches

It has been reported that Metro Bank is being investigated in the UK for allegedly receiving funds from Iran in breach of EU sanctions.

The bank has also reported itself to the US authorities in relation to possible breaches of US sanctions against Cuba.

November 12, 2019March 15, 2024 by Mark Handley

UK – 9 companies issued compound penalties for unlicensed exports

The UK’s HMRC has today announced that it has imposed compound penalties on nine separate exporters for the unlicensed exports of dual use goods, military goods and related activity controlled by Export Control Order.

The fines were between £5,000 and £90,000 in value.

October 15, 2019March 15, 2024 by Mark Handley

UK – OFSI Annual Report: enforcement statistics

OFSI has released its Annual Report for 2018-2019.

In it OFSI reports that it received 99 reports of suspected sanctions breaches with a value of £262 million.

September 9, 2019March 15, 2024 by Mark Handley

UK – OFSI’s third monetary penalty

OFSI has today imposed a fine of £146,341 against Telia Carrier UK Limited for breaches of the EU’s Syrian sanctions.

The breaches arose out of Telia facilitating telephone calls for SyriaTel which is a designated person under the EU sanctions. The phone connections were treated as “economic resources” for the purposes of the sanctions.

The fine in this instance was reduced from £300,000 after Telia opted to seek a ministerial review of OFSI’s penalty.

May 14, 2019March 15, 2024 by Mark Handley

UK – HMRC imposes fine on UK person for unlicensed exports

Her Majesty’s Revenue & Customs (HMRC) has today published details of a compound penalty of £10,234.26 imposed on a UK exporter/trader.

The penalty was in relation to unlicensed trading of body armour. The goods were not exported from the UK, but the transaction involved a UK national.

The Notice to Exporters noted that the Export Control Order 2008 requires a trade control licence when certain goods are exported from a country other than the UK, and that exporters should be aware that trafficking and brokering military goods outside the UK will need a trade control licence, even if the goods do not pass through the UK.

April 9, 2019March 15, 2024 by Mark Handley

UK – FCA imposes fine of £102m

The UK’s Financial Conduct Authority has issued a Decision Notice against Standard Chartered Bank including a fine of £102,163,200.

The fine related to KYC failings in general, with a focus on failure to conduct customer due diligence even in situations where sanctions red flags were evident. The FCA noted a lack of financial crime risk, and concerns as to the quality of the advice being given.

A particular focus were the UAE branches of the bank, and also export financing in relation to the export of military goods.

April 3, 2019March 15, 2024 by Mark Handley

UK – HMRC fines exporter £82,152.33

The UK’s HMRC has today announced that it has fined a UK exporter £82,152.33 for the unlicensed exports of military goods.

The identity of the exporter, and of the destination for the goods, were not published.

March 8, 2019March 15, 2024 by Mark Handley

UK – OFSI imposes further financial penalty

OFSI has today imposed a £10,000 penalty on Travelex Limited in relation to a £204 transaction involving the funds of a designated person.

This penalty is factually related to the same transaction as was the subject of OFSI’s first penalty.

While the fine itself is very small, that OFSI has imposed a fine in relation to such a small transaction is perhaps itself of significance.

January 25, 2019March 15, 2024 by Mark Handley

UK – HMRC compound penalties for three companies for export control breaches

It has been announced today that the UK’s HM Revenue & Customs has issued compound penalties ranging between £1,000 and £4,000 to 3 separate UK Exporters.

These related to unlicensed exports of dual use goods and export breaches controlled by The Export Control Order 2008.