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.

Finland – investigation into suspected nuclear-related breach of Russian sanctions

Finland’s Customs have issued a press release making public an investigation into the suspected export of technical documents from a nuclear power plant construction project to Russia.

The unnamed manging director of the company responsible for the construction project is identified as the person suspected of the offence.

The press release notes that the investigation is coming to an end and that, as yet, no decision on charging the individual has been made.

Estonia – criminal sanctions conviction for accepting funds from designated person

The Estonian authorities have secured a guilty plea as part of a plea deal by an individual who accepted funds from a designated person.

The accused, Tatjana Sokolova, received payments into Russian bank accounts from “The Foundation for the Support and Protection of the Rights of Compatriots Living Abroad” – a designated person under the EU’s sanctions.

The funds were withdrawn and carried into Estonia in person. The money was to be used to fund the defence of another individual who was being prosecuted for crimes against the Estonian state.

The sentence is for 360 hours of community service, with the 12-month unserved part of a 16-month prison sentence to be suspended pending completion of the community service.

Cash of €10,000 found when Sokolova was arrested has been confiscated and she was ordered to pay €1389 in court costs.

Estonia – seizure of Russian shadow fleet oil tanker

On Friday the Estonian Navy has seized an oil tanker (the Kiwala) forming part of the so-called “shadow fleet”. The Kiwala is designated by the EU.

During a routine inspection of the vessel’s documentation, it was determined that the vessel was not validly flagged in any country and did not have valid insurance.

The vessel has been detained pending rectification of the documentation and other safety issues.

Norway – investigation into shadow fleet “insurance” provider

It has been reported that police in Oslo are investigating a company called Romarine AS, as well as four individuals (two Norwegians, a Russian and a Bulgarian) relating to the insurance services provided to Russian shadow fleet vessels, and vessels sanctioned by the EU.

The allegations include the provision of faked insurance documentation purporting to show that the vessels had valid insurance, and the provision of unauthorised insurance services.

The Oslo Police were referred the case by the Norwegian Financial Supervisory Authority which has issued an order for Romarine to cease operations.

United Kingdom – sentencing for first Russian sanctions convictions

Further to last week’s post, sentencing has now been completed against Dmitrii Ovsiannikov and Alexei Owsjanikow, who were both convicted of breaches of the UK’s sanctions regime.

As per a press release from the Crown Prosecution Service, Ovsiannikov was convicted of 8 counts of breaking the asset freeze imposed upon him as a designated person, and has been sentenced to 40 months in prison for each count with each sentence to be served concurrently. He was also convicted of two charges of money laundering.

The charges relate to the purchase of a car, the payment of private school fees, deposits into bank accounts and insurance.

Alexei Owsjanikow was convicted of 2 of the charges against him, relating to the payment of school fees on behalf of his brother-in-law, and was given a suspended 15 month prison sentence and made subject of a curfew order.

United Kingdom – first criminal convictions under the UK’s Russian sanctions

It is being reported that the jury in the criminal prosecution of designated person Dmitrii Ovsiannikov, his wife Ekaterina Ovsiannikova, and his brother in law Alexei Owsjanikow have returned two guilty verdicts and one acquittal.

See our earlier posts on the progress of this case here and here.

These are the first criminal convictions obtained by the UK authorities under the UK’s Russian sanctions regime, and the first criminal conviction under any sanctions regime since 2017. It is also a rare example of the prosecution of a designated person.

Ekaterina Ovsiannikova was acquitted on four counts of circumventing sanctions arising from payments to her husband of £76,000 in 2023.

Alexei Owsjanikow was acquitted of several counts relating to access to a car, arranging car insurance and use of a bank account. He was, however, convicted of two counts of circumventing sanctions relating to the payment of £41,027 in private school fees.

Dmitrii Ovsiannikov was convicted of six of the seven counts he was charged with, all relating to breaches of the asset freeze imposed upon him by reason of his status as a designated person.

Sentencing will take place in due course, and it is to be hoped that the judge’s Sentencing Remarks are made public.

United Kingdom – export control compound penalties issued totalling £3.7m

Yesterday the UK’s HMRC issued a Notice to Exporters publishing three recent compound penalties issued to exporters.

In line with HMRC policy when agreeing to a compound penalty resolution, the information provided on the offending, the offender, and the co-operation provided is limited, although in this instance it is specified that the penalties do not relate to sanctions breaches. The detail available states:

The settlements relate to unlicensed exports of military-listed goods and related activity prohibited by The Export Control Order 2008 and contrary to The Customs and Excise Management Act 1979. These do not relate to sanctions offences.

The 3 settlements agreed with UK companies were:

  • January 2025 – £10,900.00 was paid for export license breaches in relation to the export of military goods controlled by The Export Control Order 2008
  • February 2025 – £431,232.20 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008
  • February 2025 – £3,231,762.40 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008“.

Switzerland – Attorney General’s Office provides details on two ongoing criminal sanctions cases

The Annual Report of the Swiss Attorney General’s Office (OAG) contains details on two ongoing criminal sanctions cases which it has taken over from SECO. Both cases arise under Switzerland’s Russian sanctions.

In one the OAG state that they have conducted search at eight residential properties in the cantons of Lucerne, Zug and Nidwalden. The investigation is said to relate to both an asset freeze imposed on a designated person and suspected breaches of the Swiss Embargo Act.

Assets which are the subject of “super-provisional freezing” as part of this investigation are said to total CHF 1.3 billion (or c. €1.39 billion).

Less information is given on the second investigation other than that it is “in connection with suspected sanctions violations by a Swiss company via subsidiaries abroad”.

Luxembourg – CSSF issues fine for AML and sanctions compliance failings

A fine imposed by Luxembourg’s financial services regulator on the Luxembourg subsidiary of the Allianz Group has become public after a court dismissed an appeal.

The fine of €283,000 was first imposed on 25 March 2022, but only published on 4 April 2025 after the conclusion of the court challenge.

One of the compliance issues identified included failures to “provide evidence of complete initial and ongoing name screening against … sanctions lists”.

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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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