Finland – trial begins in prosecution for exporting trucks and trailers to Russia

Further to our earlier post regarding the prosecution for exporting 135 trucks and 29 trailers from Finland to Russia, it is being reported that the criminal trial has started this week in Helsinki.

The prosecution are seeking a four year jail term for the individual and a fine for the company involved.

It is alleged that in 2022 and 2023 the vehicles were declared as bound for Kazakhstan and Türkiye and only transiting via Russia, but were actually exported to Russia.

UK – OFSI imposes Russian sanctions fine of £1,000,920.59

The UK’s Office of Financial Sanctions Implementation has issued a Penalty Notice against Sabre Global Technologies Limited (SGTL) imposing a fine of just over £1m against this UK entity.

SGTL continued to provide services to JSC Ural Airlines after that entity was designated in May 2022 and after the fact of the designation was communicated to SGTL by its lawyers on the same day.

Three payments were made to SGTL by JSC Ural Airlines between June and September 2022 totalling $906,576.30. These payments were blocked by SGTL’s bank.

In October 2022 SGTL self-disclosed the breaches to OFSI.

The Penalty Notice identified the following breaches:

  1. by invoicing JSC Ural Airlines SGTL made available a financial benefit (and so “funds”) in the form of the discharge of a debt obligation by the airline;
  2. by continuing to provide the airline with access to a product providing travel content up until 6 December 2022, SGTL was making an “economic resource” available to the airline;
  3. by exploring alternative payment routes to avoid the UK, including the making of a “test” payment of $200 to SGTL’s US bank account, SGTL was circumventing the UK’s sanctions in breach of regulation 19.

These breaches, especially the continued offering of SGTL’s product, were assessed as having a value of £2,634,001.54.

OFSI assessed the breaches as being in the “most serious” category given the value, the duration and the efforts at circumvention. The fine was assessed at the maximum of 50% of the value, and then the company obtained a 20% discount to reflect self-disclosure.

The Penalty Notice makes several other “Notes on Compliance”:

  1. firms must not test, reroute, restructure, or otherwise manipulate payment pathways in order to avoid, evade, or defeat the effect of UK sanctions. Attempts to engineer alternative channels, including staging of payments through third countries, may constitute circumvention and a breach in and of itself. Such conduct will be treated as aggravating and will significantly increase the seriousness of any case“;
  2. firms must be vigilant in identifying what may constitute an “economic resource” under UK sanctions regulations. Economic resources are assets of every kind, whether tangible or intangible, movable or immovable, which are not funds but can be used to obtain funds, goods, or services. Services that can be exchanged, directly or indirectly, for funds, goods, or services may constitute an economic resource even if they are intangible or provided digitally. In particular, firms should not assume that software, data services, or digital tools fall outside the scope of financial sanctions. A service that enables a designated person or entity to generate revenue, maintain operations, or otherwise obtain an economic advantage may amount to making an economic resource available“; and
  3. Although it is reasonable for a firm to take some time to assess the nature and extent of the breach, or seek legal advice, this should not delay an effective response to the breach. In practice, firms should contact OFSI early to inform us of a breach or potential breach. Where full disclosure is not possible, firms should make an early disclosure with partial information on the basis that it is still working out the facts and will make a further and full disclosure as soon as possible“.

UK – captain of detained oil tanker charged with sanctions offence

Further to our earlier post on the UK’s seizure of the Smyrtos oil tanker, the UK’s National Crime Agency has announced that Indian national Ajay Pant, has been charged with “directly or indirectly supplying or delivering by ship prohibited oil / oil products from Russia to a third country during the period of June 2026 in contravention of Reg 46Z9B“.

The National Crime Agency’s press release does not state the basis for the UK’s criminal jurisdiction, but the UK’s sanctions regulations apply to actions in the UK’s “territorial sea”, which is elsewhere defined as being the breadth of 12 nautical miles from the UK.

Poland – sanctions enforcement statistics with nearly 2500 cases registered

A lengthy article in the Belarusian Investigative Center on alleged sanctions circumvention regarding Belarusian wood pellets, includes data obtained from the Polish Prosecutor’s office on sanctions enforcement:

  • 187 criminal cases were pending as of mid-2026 for circumvention of sanctions against Belarus and Russia (see our earlier post from May 2026 where the figure was 191);
  • nearly 2,500 sanctions cases have been registered;
  • 85% of these 2500 cases, or over 2100, concerned Belarus; and
  • At least 91 criminal proceedings were specifically related to wood-processing products.

UK – seizure of shadow fleet tanker “Smyrtos”

On Sunday British armed forces boarded and detained the “shadow fleet” oil tanker Smyrtos.

While British forces have assisted other nations previously, this is the first time that the UK has detained a shadow fleet vessel.

The vessel was in international waters in the English Channel, and the press release refers to UNCLOS Article 110 as giving a power to exercise “a right of visit” where there are reasonable grounds to suspect the vessel is without nationality”.

The vessel is now anchored off the south coast of England.

BBC reporting notes that the vessel claims a Cameroon flag, and that it has changed its flag multiple times since it was designated by the UK in July 2025. The same reporting has added that a 38-year old Indian national has been arrested on suspicion of offences under the UK’s Russian sanctions.

Lloyd’s List, is reporting that Cameroon had previously expelled the Smyrtos from its registry.

Our European Vessel Seizure Tracker has been updated.

Belgium – three convicted of Russian sanctions breaches

Reuters is reporting that three individuals have today been convicted of Russian sanctions offences.

The offending involved the shipment of goods for the Russian defence sector via third countries including Hong Kong and Kazakhstan. The goods are described as “sanctioned goods, including rare earths, an explosive detector and ​a defence-related machine”.

The first defendant, named in the reporting as Victor Labin, was given an €80,000 fine and a five year prison sentence, with one year of that suspended.

The second defendant, reported to be Ruslan Labin, and tried in absentia was sentenced to six years in jail and an €8,000 fine.

The third defendant, named only as P.I., was given a three year sentence, suspended for five years, and an €8,000 fine.

UK – two convicted for tens of millions in prohibited arms sales

HM Revenue and Customs has issued a press release relating to yesterday’s conviction of David Greenhalgh and Christos Farmakis on multiple counts (nine and ten respectively) of unlawful exports of military hardware in breach of UK sanctions and arms embargos under the Export Control Order 2008.

Mr Farmakis was tried in absentia with HMRC stating that he is thought to currently be in Greece and that HMRC is “working with international partners to bring him to the UK to face justice”.

Sentencing is due to take place in July, with the judge reported as saying that Mr Greenhalgh should expect a lengthy custodial sentence.

The unlicensed sales and exports were to Sudan, South Sudan and Libya between 2009 and 2016 and were largely of ex-Soviet equipment including “ex-Soviet jets, surface-to-air missile systems, anti-tank missiles, thousands of assault rifles and other controlled goods”.

The transactions were conducted through Mr Greenhalgh’s companies and involved circuitous transport routes as well as faked end-user certificates.

Poland – individual fined c. €4.7m for sanctioned luxury car exports to Russia

Poland’s National Tax Administration has issued a press release confirming the imposition of a PLN 20,000,000 (c. €4.7m) fine on an unnamed entrepreneur.

This is separate from another fine of the same amount that was imposed in April on a company for luxury car exports.

The entrepreneur exported 177 cars and one motorbike between January and June 2023 each valued at over €50,000 in breach of the EU’s prohibition against the export of luxury goods to Russia with a total value of over €19m.

My thanks to Dr Marcin Lukowski for pointing me to the announcement.

Poland – two charged with sanctioned exports of dual-use goods to Russia

Poland’s ABW (Agency for Internal Security) has issued a press release related to the charging of two individuals, Eduard K. and Krzysztof J., on suspicion of exporting dual use goods to Russia in breach of the EU’s sanctions.

The equipment was a CNC machine tool and a thermal chamber for metalworking. The equipment was purchased in Germany and transported to Poland before being shipped to Turkey for further export into Russia.

The goods were stopped from being exported and the two suspects have been detained since September last year.

The press release notes the availability of a sentence of not less than three years as well as confiscations.

Netherlands – Customs launch major investigation into vessel exporting to Russia

It is being reported that Dutch Customs have launched a major investigation includes raids on premises in Rotterdam and Amsterdam, searches on board a container vessel and the arrest and detention of the captain.

The vessel in question routinely sails between St Petersburg and Rotterdam. Dozens of containers on board the vessel have been found with goods suspected of breaching the EU’s sanctions. The containers are said to show signs of attempts to conceal the contents.

Of the goods identified, the containers carried large quantities of car parts which can be used in passenger vehicles as well as trucks. Also found was motor oil.

The same report also indicates that the investigations continue into: i) a company suspected of sanctioned imports of timber (see our earlier post), with the report noting that trial is anticipated in 2027); and ii) the company suspected of supplying goods and services to shadow fleet vessels (see our earlier post).

© 2009- Duane Morris LLP. Duane Morris is a registered service mark of Duane Morris LLP.

The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

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