In a first for this blog, we can report on sanctions enforcement activity in Portugal.
Three judgments from the Lisbon Court of Appeal reveal ongoing investigations into alleged breaches of the EU's regulation 833/2014.
The judgments are each the dismissal of appeals by anonymised persons who have had bank accounts frozen pending the outcome of the the criminal investigations in question. In each case the investigation appears to be focussed on alleged breaches of regulation 5b of 833/2014 and the €100,000 deposit cap first introduced in February 2022.
The judgments are from:
- 24 May 2023: in this case it is alleged that a Russian national (named only as YS) transferred over €1.8m for the purchase of real estate in Portugal in February and June 2022. The judgment mentions that YS had been a senior manager within Gazprombank.
- 6 February 2025: in this case it is alleged that two Russian nationals (named only as AA and BB) transferred $6m from accounts in Russia and Austria in February and October 2022, and another €4.7m in February and March 2022 There is also an allegation that the transfers related to Tatyana Golikova, who is a designated person under the EU's sanctions.
- 11 March 2025: in this case it is alleged that two Russian nationals residing in Russia (named only as AA and BB) transferred several hundred thousand euros to bank accounts in Portugal.
Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.
