European Sanctions Enforcement

January 6, 2025 by Mark Handley

Finland – sanctions enforcement statistics: over 900 investigations, hundreds of fines and dozens of convictions

Press reporting in Finland has provided an update on Finland’s sanctions enforcement.

The update provides:

over 900 preliminary investigations commenced by Finnish Customs:
- 13 started between 2018 and 2021;
- 306 started in 2022;
- 492 started in 2023; and
- 83 started in 2024 (January to September, with an uncertain number since then)
“More than half” involved minor regulatory offences and have been resolved by monetary fines without recourse to the court system. These cases are further described as: “The fine cases mainly concern private individuals who have exported small quantities of banned goods across the border. Private individuals have exported, for example, luxury goods, not equipment needed by the military“.
“Dozens” of convictions and fines imposed by the courts for more serious offences. These are described as: “characterized by planning, systematicity and the pursuit of significant financial gain. Most often, they involve equipment needed on the front line. … The perpetrators in such cases are typically small or medium-sized export or logistics companies“.

The report provides no further details on the precise number of fines, the amount of fines, or other sentencing involved.

A separate report notes that the Finnish Navy has established a controlled area in the Gulf of Finland where Russian-linked vessels are inspected. This de facto maritime detention zone is encircled by Finnish naval forces and that currently 20 Russian “shadow fleet” vessels are “under scrutiny, with several facing potential long-term detention“.

January 2, 2025January 2, 2025 by Mark Handley

Finland – sanctions investigation closed into returned Russian art

In April 2022 Finnish Customs seized over 200 pieces of art being shipped back to Russian museums such as the State Hermitage Museum and the Tretyakov Gallery.

It is now being reported that at that time an investigation was commenced by Finnish Customs working with the Finnish Foreign Ministry as to whether permitting the onward transit of the objects and artefacts, or the shipments themselves, would amount to breaching EU sanctions.

The artefacts were later allowed to travel on to Russia while the investigation continued.

As of 24 December 2024, it is now being reported (in the linked article above) that the investigation has concluded with no further action to be taken.

January 2, 2025January 2, 2025 by Mark Handley

Bermuda – trust company fined $600,000 for sanctions and AML compliance failings

On 30 December the Bermuda Monetary Authority announced the imposition of a fine of $600,000 on Meritus Trust Company Limited for a series of AML and sanctions compliance failings.

In terms of sanctions compliance the failing was specified as “An overreliance on manual processes to implement international sanctions policies and procedures and sanctions screening“.

The BMA’s on-site investigation was commenced in June 2022 and the company was then given a deadline of July 2023 to complete the necessary remediation. The BMA was satisfied with the company’s efforts and noted a number of mitigating factors such as a low risk of loss to clients, co-operation, the remediation efforts, and the company’s overall culture of compliance.

This is a rare example of a sanctions enforcement fine being imposed in one of the UK’s overseas territories or crown dependencies. The only other example known (to this blog) are the fines and other punishments imposed in Guernsey in 2015/2016.

January 2, 2025January 2, 2025 by Mark Handley

Latvia – more than 100 criminal cases for sanctions breaches commenced during 2024

It has been reported that the Latvian authorities commenced 100 criminal cases for suspected sanctions violations during 2024.

In late October 2024 the figure was reported as 94, meaning that the final weeks of the year continued to see new criminal cases started.

The cases appear to be predominantly related to breaches of trade sanctions and the reporting states that the prohibited products included “engines, steel products and optical devices”.

December 20, 2024December 20, 2024 by Mark Handley

Finland – aircraft detained for suspected involvement in sanctions evasion

It is being reported that a Lithuanian-registered aircraft being flown from Latvia to Russia via Finland has been intercepted and detained at Helsinki airport due to suspicions of sanctions evasion.

The pilot of the aircraft has been reported to have been involved in a number of previous alleged aircraft sales to Russian customers.

December 20, 2024December 20, 2024 by Mark Handley

Estonia – person detained for alleged breach of designated person’s asset freeze

It is being reported that the Estonian authorities have arrested and detained a 65-year old named only as Tatjana, for allegedly managing and handling funds on behalf of the Foundation for the Support and Protection of the Rights of Russian Compatriots Living Abroad, which is a designated person under the EU’s sanctions.

It is alleged that Tatjana received €50,000 from the Foundation and used the money to fund a person’s defence in an ongoing criminal trial in Estonia.

December 20, 2024December 20, 2024 by Mark Handley

United Kingdom – three penalties imposed by HMRC for breaches of Russian trade sanctions

On 4 November 2024, HMRC published a Notice to Exporters regarding a compound penalty of £58,426.45 imposed for breaches of Russian trade sanctions.

The Notice included the line:

“Since February 2022, HMRC has issued six compound settlements against UK companies that have breached the Russia sanctions regulations for a total of £1,363,129, including one in August 2023 for £1 million“.

This struck a chord because, as captured in this blog, only three compound penalties had been publicly imposed by HMRC for breaching Russian sanctions. So a Freedom of Information request was made about the other three.

The response is here.

FOI2024_232370 Download

The response discloses details of three compound penalties (totalling c. £237,000) from August and September 2022 and April 2023. These had each been previously published, but had not previously been described as relating to Russian sanctions.

August 2022 – £1,000.00 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
- This penalty was previously described as relating to “unlicensed exports of dual-use goods”.
September 2022 – £19,689.20 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
- This penalty was previously described as relating to “unlicensed exports of dual-use goods”.
April 2023 – £217,012.50 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
- This penalty was previously described as relating to “unlicensed exports of dual use goods”.

It is unclear why these penalties were not previously described as relating to breaches of Russian sanctions.

The FOIA request also asked for the names of the individuals or companies which were the subject of the penalties; whether any had self-reported; and what (if any) confiscation of the proceeds of crime was applied. These questions were not answered.

December 17, 2024December 17, 2024 by Mark Handley

Estonia – police and border guards conduct over 240 inspections of Russian “shadow fleet” vessels

It has been reported that Estonia’s police and border guards have between them conducted over 240 inspections of vessels in waters of Estonia’s economic zone in the last 6 months. Estonia adopted the policy of conducting inspections in June of this year.

The vessels are said to belong to Russia’s so-called “shadow fleet” and the inspections relate to verifying compliance with requirements such as valid insurance.

December 17, 2024 by Mark Handley

United Kingdom – company convicted of export control violations

His Majesty’s Revenue and Customs (HMRC) has announced the conviction of the company EDM Limited on three counts of exporting controlled military goods without the appropriate licence.

The good in question were military flight simulators valued at £38,967.68.

The company was fined £89,359.80, including costs, but HMRC’s Notice does not mention whether a confiscation order was also made.

EDM Limited had been offered a civil compound penalty to resolve the matter but had not accepted the offer in time and so the case went to trial.

December 10, 2024December 10, 2024 by Mark Handley

Netherlands – third defendant found guilty in sanctioned aircraft parts export prosecution

Further to our earlier posts from 8 October and 7 October relating to the conviction of a company and individual for exporting aircraft parts to Russia in breach of EU sanctions, the Rotterdam District Court ruled on 22 November that the third co-defendant is also guilty.

The judgment is here.

The individual was an employee of the Ministry of Defence and was first arrested in September 2023 (see our earlier post).

The conviction was based on the export of parts via Tajikistan, Kyrgyzstan, Turkey the UAE and Serbia. The Defendant was also convicted of falsifying documents and of a minor fire arms charge.

The court accepted findings of PTSD by court psychologists and the probation service.

At sentencing the court stated: “In view of the seriousness of the proven facts, from the point of view of general prevention, a prison sentence of considerable duration is in principle appropriate“.

In the circumstances of the defendant, however, the custodial sentence was limited to the period of pre-trial detention with a further period of 195 days suspended for two years. In addition 240 hours of community service was imposed.

The individual was also disqualified from acting as a company director for three years.