Poland – seizure of 5 tons of aviation tyres bound for Russia/Belarus

Poland’s National Tax Administration has issued a press release, announcing the seizure of 5 tons of aviation tyres.

The discovery was made through a routine inspection of a truck by the Lublin Customs and Tax office.

The declared goods were automobile tyres. The sender of the tyres was an unnamed company in Spain, and the declared recipient was said to be in Azerbaijan.

The goods were detained and criminal proceedings have been instituted.

Poland – multiple raids and arrests for suspected import of timber in breach of Russia and Belarus sanctions

Poland’s National Tax Administration yesterday issued a press release detailing raids and arrests in three provinces.

The three arrested individuals have been charged and are in pre-trial detention. They are suspected of importing birch plywood from Belarus and Russia in breach of EU sanctions.

The Tax Administration has conducted a number of similar investigations in recent months, which have not previously been included in this blog:

24 April 2025 – The Pomeranian branch of Poland’s National Tax Administration has conducted raids in Gdynia. Thirty pallets of timber suspected to have been imported from Belarus and Russia were seized.

9 April 2025 – The Pomeranian branch of Poland’s National Tax Administration has conducted inspections of timber purportedly imported from Tunisia at the Baltic Container Terminal in Gdansk, and seized over PLN 1 million in timber on suspicion that it was imported from Belarus and Russia in breach of EU sanctions.

28 February 2025 – The Lublin branch of the National Tax Administration has seized 1800 pallets of plywood suspected of being imported from Belarus and Russia via China and Kazakhstan. The press release adds that 15 sets of proceedings are being prepared as a result of the seizures valued at PLN 3.2m.

November 2024 – raids were conducted in seven provinces in relation to an ongoing investigation into suspected imports of timber from Belarus and Russia in breach of Eu sanctions.

United Kingdom – OFSI imposes £5,000 fine for refusing to respond to information request

The UK’s OFSI has announced a £5,000 monetary penalty imposed on Svarog Shipping & Trading Company Limited.

The fine was for failing to respond to an information request from OFSI in breach of regulation 74(1)(a) of the UK’s Russian sanctions regulation.

The Penalty Notice states that the request for information was made in the context of a wider “large and complex investigation into suspected breaches” of the UK’s sanctions in relation to Sovcomflot. That investigation is, presumably, ongoing.

Germany – CJEU decision on sanctions conviction for exporting cash to Russia

The Court of Justice has issued a preliminary ruling arising from the criminal conviction in Germany of an individual who was stopped at Frankfurt Airport in May 2022 attempting to export €13,800 in cash to Russia.

The individual’s argument was that the funds fell within the “personal use” exception in article 5i(2)(a) of regulation 833/2014, as they were for intended for various medical procedures including dental treatment, fertility treatment and plastic surgery.

The Court of Justice has decided that a “strict interpretation of th[e] exception” was appropriate, that medical treatments do not fall within the exception, and that the exception was for “cash necessary to obtain essential goods and services in order to meet their needs during their travel and stay in Russia”.

The reference to the CJEU was from the Oberlandesgericht Frankfurt am Main, which was hearing an appeal from the original conviction.

Netherlands – appeal brought to increase 18 month sentence for Russian exports

In an earlier post, we reported on the October 2023 sentence of an individual to 18 months in jail, and a fine of €200,000 imposed on the company operated by the individual.

It is now being reported that an appeal has been brought by the Dutch Public Prosecution Service (the “OM”) seeking to increase the sentence.

The OM are seeking a three-year custodial sentence, a five-year ban from the individual acting as a director, and confiscation of €72,697.71 of the proceeds of the sanctions breaches.

It is reported that the appeal is based on the deliberate nature of the offending with the export of sanctioned goods to Russia via third countries including the Maldives and Kazakhstan.

There is no appeal in relation to the fine of €200,000 imposed on Woerd-Tech BV.

Netherlands – prosecution of shipbuilder for alleged exports to Russia

The Dutch Public Prosecution Service has announced that it has charged the Dutch shipbuilding company Damen with an offence under the Dutch Sanctiewet. Other (non-sanctions) offences are also alleged.

The alleged breach of sanctions is said to have taken place in 2022 and to have involved exports to Russia of goods and technology.

The company has issued its own release which states in part:

“With regard to the suspicion of violating the Sanctions Act, Damen can report that it has always acted in accordance with the applicable sanctions packages and that full transparency has been exercised about its activities. Damen is therefore surprised that one case from June 2022 is now being submitted to the court. This is a case involving the supply of a very limited number of civilian cranes to Russia. This delivery took place within the sanctions legislation in force at the time”.

Lithuania – OLAF and Lithuanian Customs raid company suspected of sanctions breaches

The European Anti-Fraud Office (OLAF) has issued a press release reporting on a joint operation with Lithuanian Customs.

After a joint investigation officers from both bodies took part in a raid in the Vilnius region.

The investigated conduct is said to involve the shipment of sanctioned goods to Russia through Central Asian countries. According to the Lithuanian Customs press release, the raised company was said to be providing “transport, logistics and forwarding services”.

Sanctioned goods valued at approximately €1.5 million, weapons and cash were seized as part of the raid. Four individuals were arrested as part of the raid.

Latvia – updated sanctions enforcement statistics

The Financial Intelligence Unit of Latvia has published its Financial Integrity Newsletter for its activity during 2024.

This includes a range of sanctions enforcement-related statistics:

  • 451 suspicious activity reports in relation to suspected sanctions breaches;
  • attempted cash exports to Russia of €18.9 million stopped;
  • more than 8,500 shipments across Latvia’s border with Russia stopped, of which 89% were exports and 11% were imports; and
  • 392 criminal proceedings started between 2022 and the end of 2024.

The Newsletter does not provide figures on the outcomes (to date) of the 392 criminal proceedings.

Estonia – details of eleven Russian sanctions convictions

Further to the earlier post about Estonia having obtained 8 criminal convictions during 2024, we can publish details of the criminal convictions for breaches of the EU’s Russian sanctions that have been published on Estonia’s searchable gazette of published judgments.

As well as one conviction obtained in 2022, below we are publishing summaries of seven of the convictions from 2024 and three from 2025 (not including the conviction made public on 16 April 2025) as well as machine translations of the respective judgments.

The sentences range from fairly small monetary fines up to custodial sentences of 5 years in jail.

  1. Judgment of 10 October 2022 – Petr Rafalovich (a Belarus national) was convicted and given a two month sentence following which he was to be deported to Belarus and given a five-year ban from re-entering Estonia. He was also ordered to pay a penalty and costs of €1,250.40.

The offence was the attempt to export a 3D printer and an electromagnetic positioner. Mr Rafalovich was carrying false papers indicating the goods were destined for an Armenian company, as well as other papers indicating the true recipient to be a Russian company.

2. Judgment of 5 February 2024 – Victor Manilo was convicted and ordered to pay €2,680 as a fine.

The offence was the attempted export of €14,000 in physical currency to Russia.

3. Judgment of 14 February 2024 – Galina Sergejenkova was convicted and ordered to pay €3,960, such payment suspended for a probationary period of 18 months. A separate payment of costs and a penalty of €1,434.96 were to be paid straightaway.

The offences were two attempts to transport physical currency (of €900 and €1,000 respectively).

4. Judgment of 27 February 2024 – Evgeniy Kozlovtsev was convicted and given an eight month sentence suspended for a probationary period of 18 months. He was also ordered to pay a penalty and costs of €1,430.

The offence was the attempted export to Russia of two bottles of wine greater than the €300 luxury threshold. It was the man’s second attempt at such exports.

5. Judgment of 8 March 2024 – Aleksei Bond was convicted and given a five month prison sentence suspended for a probationary period of 18 months. He was also ordered to pay a penalty and costs of €1,555.

The offence was the attempted export of a luxury watch valued at €13,900 to Russia.

6. Judgment of 27 March 2024 – Lev Pylkin was convicted and ordered to pay a penalty of €1,190, as well as confiscation of the cash he attempted to export to Russia.

The offence was the attempted export of €2,560 in physical currency across the border to Russia. He had previously attempted to export cash at which time the details of the offence had been explained. The judgment is the dismissal of an appeal against the conviction and sentence.

7. Judgment of 17 October 2024 – Ruslan Sibilev was convicted and ordered to pay a fine of €79,557.50 as well as confiscation of a large number of rifle scopes, binoculars and other equipment.

The offences were committed through the acquisition of a range of sanctioned goods from a Portuguese company and an Austrian company, with Sibilev acting to coordinate further transport for the export of the goods to Russia. The orders were placed between May 2022 and April 2023. The total value of the goods ordered was nearly €1 million.

8. Judgment of 16 December 2024 – Oleg Osipov was convicted and sentenced to 8 months in prison suspended for a probationary period of 18 months. He was also ordered to pay €13,230, including 100% of the fee earned as part of the sanctioned transactions.

The offences were committed through Osipov providing a brokering service for the export of luxury goods to buyers in Russia between May and July 2023. The goods included electrical goods, phones, alcohol, navigation systems and various automotive parts. Osipov contracted with others to deliver the goods and took a brokering fee for arranging the transactions.

9. Judgment of 14 February 2025 – Demyan Belyakov was convicted and sentenced to 5 years in jail and ordered to pay €8,231 in costs and other penalties. In addition a large volume of goods were confiscated.

The offences were committed through the actual and attempted export to Russia of hundreds of silencers and firearm flash suppressors between February and June 2024.

10. Judgment of 20 February 2025 – Andrei Klychkov was convicted and sentenced to serve two months in prison plus a further period of 2 years and 10 months suspended for a probationary period of 4 years. €5,000 was also confiscated and he was ordered to pay costs of €2,581.

The offences were committed by the attempted export of parts for firearms, to Russia.

11. Judgment of 21 March 2025 – Aleksandr Ivantsov was convicted and sentenced to 4 years, 11 months and 27 days (after deducting 3 days of pre-trial detention) suspended for a probationary period of 5 years and other conditions including a requirement for prior permission to be away from his house for more than 15 days, and permission to leave Estonia. He was also ordered to pay €2,215 and had 70,550 rubles, and other goods, confiscated.

The offence was committed by the attempted export of six pairs of night-vision binoculars.

This case is related to that above for Ruslan Sibilev with Mr Ivantsov being one of the people used to try and physically carry the goods across the border into Russia.

Netherlands – timber confiscations from companies already under investigation for alleged sanctions violations

As reported in our post from June 2024, at that time the Dutch FIOD conducted raids and arrested two individuals suspected of importing Russian-origin timber in breach of the EU’s sanctions.

FIOD has now announced a further round of seizures from the same companies. The allegation is that the companies have continued to trade in Russian timber during the pendency of the ongoing investigations into their activities.

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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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