Germany and Bulgaria – raids at German manufacturer with three charged with sanctions offences

Last week more than 140 officers from the Munich Customs Investigation Office and the Munich I Public Prosecutor’s Office conducted raids on several premises in Munich and Baden Württemberg.

The subject of the raids was a machine tool manufacturer suspected of exporting 20 machines valued at more than €5.5m to Russia in breach of the EU’s sanctions.

It has subsequently been reported that the company was Spinner GmbH.

It has also now been reported that three individuals have been charged with sanctions offences. They have not been named.

The press release from the Munich Public Prosecutor’s Office also stated that the Bulgarian authorities conducted contemporaneous raids at premises in Bulgaria with support and coordination from Eurojust.

Guernsey – licence revoked and fines imposed on financial services firm and individual

The Guernsey Financial Services Commission has issued a release regarding the imposition of several fines and the revocation of regulatory authorisations for a firm and an individual.

The firm ITI Trade Ltd was fined £175,000, and Mr Alexi Filatov was personally fined £35,000.

An order has been issued preventing Mr Filatov from holding a regulated position for 2 years and 10 months.

ITI Trade Ltd agreed to surrender its licence.

The compliance failings were first identified by the Commission in 2019, and the firm undertook (or purported to undertake) various remediation programmes (the results of which were doctored for the purpose of submissions to the Commission), before the Royal Court appointed Administration Managers over the firm in July 2022.

The failings relate to a lack of sanctions and AML compliance, due diligence and screening with the Guernsey entity “used to appear to provide investment services from Guernsey, when in reality much of the business was conducted in Russia”.

Estonia – sanctioned Russian timber enforcement

Estonia’s Customs has issued information on its current enforcement activity in relation to sanctioned Russian timber.

While noting the use of Kazakhstan, China and Georgia as prominent third countries used for attempts to import Russian timber, Estonian Customs notes:

  • 618 inspections conducted on imported timber;
  • 79 shipments refused entry to Estonia;
  • 100 proceedings based on a fraudulent origin of the timber commenced; and
  • 23 sanctions violations identified.

The release does not identify the outcomes of the 23 identified violations.

United Kingdom – OFSI imposes a fine of £300,000 for breach of EU Russian sanctions

OFSI has published a Penalty Notice fining a UK company Markom Management Limited (“MML”) £300,000 for breaches of The Ukraine (European Union Financial Sanctions) (No.2) Regulations 2014.

The fine was for issuing a payment instruction to return an overpayment of £416,590.92 to a Russian bank account belonging to a designated person.

The fine was initially set at £400,000, but was reduced through the ministerial review process.

This penalty is noteworthy for a number of reasons:

  1. This enforcement action dates from events in 2018. While underscoring the slowness of OFSI’s enforcement steps it also reinforces the lack of a limitation period for the UK’s sanctions, and the fact that the UK continues to enforce the EU sanctions that were in place before Brexit.
  2. The self-reporting by MML was considered insufficient to trigger a discount to the imposed penalty.
  3. The conduct that warranted the penalty was a person in the UK sending a payment instruction to a bank in Russia to transfer funds to another bank in Russia. This is a reminder of the broad reach of the UK’s criminal jurisdiction when it comes to communications sent in or out of the jurisdiction. This penalty notice sits uneasily alongside the recent civil decision in Celestial Aviation Trading Ireland Ltd & Ors v Volga-Dnper Logistics BV [2025] EWHC 1156 (Comm).

Denmark – raids, arrests and individuals and company charged in Russian sanctions prosecution

After press reporting had published allegations that the Danish paint company Flügger may have been continuing to trade with Russian customers via third countries in breach of EU sanctions, on 26 June the National Unit for Special Crime (NSK) conducted raids on the business premises of Flügger, and the homes of the company’s CEO and CFO.

The CEO and CFO were arrested as part of the raids, and have both been charged with sanctions offences as has the company itself.

The company has issued a press release confirming the investigation and stating that it has been deceived by distributors in Kazakhstan, Estonia, Azerbaijan and Kyrgyzstan.

Estonia – lengthy custodial sentence for sanctions offences

Estonia’s Office of the Prosecutor has issued a press release regarding an agreed settlement with Pavel Kapustin convicting him of sanctions offences as well as espionage and supplying false information.

The man was sentenced to 6.5 years’ jail and assets valued at €90,000 were confiscated. The press release does not break down the sentence by offence.

The man took orders for luxury goods from Russian customers and arranged for their transport to Russia in breach of the EU’s sanctions.

This is the sixth custodial sentence handed down in Estonia for sanctions offences so far this year.

Germany – 5 year sentence for and confiscation of c. €5m for sanctioned cars exports to Russia

As first reported in Global Sanctions, and as per a press release by German Customs, the Marburg Regional Court on 8 July has sentenced an individual to 5 years in jail for exporting luxury cars to Russian breach of the EU’s sanctions.

The man was convicted of 71 separate counts.

The court also confiscated approximately €5m as the gross proceeds of the cars sales.

Greece – investigation into alleged imports of sanctioned Russian birch

The NGO Earthsight has published an article on its website stating that in January this year it tipped off the Greek authorities to a shipment of allegedly sanctioned Russian birch plywood coming from the company Tianma Lvjian known to “launder” Russian birch plywood.

Earthsight adds that it has now “learned that Customs authorities in Greece have detained it and several other shipments from the same supplier. Investigations are ongoing.”

While Russian birch plywood has been the subject of numerous enforcement actions, this is are rare example of a sanctions investigation in Greece reaching the public domain.

Netherlands – two sanctions judgments: i) individual given 3 years prison sentence; and ii) confiscation of €1m in unlawful profits

The Dutch courts have published two sanctions judgments.

In the first case, the District court of Rotterdam has sentenced an individual to three years in jail.

The individual was convicted for providing technical assistance to a person in Russia or for use in Russia of different computer files containing information on the manufacture of microchips. The files were shares by Google Drive and Telegram between January 2023 and August 2024.

The defendant was acquitted of charges of physically taking similar files to Russia on USB sticks.

On sentencing the judgment stated:

Providing advice to and sharing technology with Russia is extremely serious. It can contribute to strengthening military or strategic capabilities of that country, which has an impact on Ukraine and can indirectly affect international security and stability. It is therefore a serious offence. … The nature and seriousness of the facts justify a prison sentence of considerable duration. The fact that the files would contain outdated information is irrelevant because this information can be of great value to a country with a (much) lower level of knowledge. It must be prevented that a country at war can benefit in any way from advanced technological knowledge. After all, for that reason, an extensive package of sanctions has also been agreed against Russia, among others“.

In the second case, the District Court of Amsterdam has issued an order confiscating €1,013,956.00.

The unnamed corporate defendant had been provided goods and services in relation to the construction of the Kirch Bridge, and had been convicted on 28 November 2024 (our previous post here), with a fine of €120,000 imposed.

The court calculated that the gross revenue obtained in breach of sanctions was €2,711,085, but allowed certain costs including internal time incurred and the cost of insurance resulting in a final confiscation of €1,013,956.

The effect of this is that revenue of nearly €1.7m obtained in breach of the EU’s sanctions was retained by the convicted company.

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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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