Hungary – fine imposed on individual for imports from Russia

It is being reported that Hungarian authorities have reached a settlement to resolve the prosecution of an individual identified as M.M.

The prosecution was based on importing car parts from Russia, via Belarus, in breach of the EU’s sanctions.

The imports are said to have been valued at HUF 35 million (€84,500), and the agreed settlement was for a fine HUF 1 million (€2,400), the confiscation of the imported parts and the payment of legal costs.

This is the first known example of an enforcement action in Hungary.

Germany – sanctions investigation into alleged exports to Belarus by politician’s company

It is being reported that a German customs investigation has been commenced into the business affairs Jörg Dornau who is an MP in the Saxon state parliament.

It is alleged that he arranged for the export of machinery to Belarus in breach of EU trade sanctions.

It is alleged that the goods were first sent to Kazakhstan before then being on-shipped to a company in which the politician has interests in Belarus called Zybulka-Bel.

The press article mentions that before any prosecution could be brought the MP’s immunity would need to first be lifted.

Latvia – prosecution for exports to Belarus in breach of sanctions

It is being reported that a Belarusian businessman resident in Latvia is being prosecuted for alleged exports to Belarus in breach of the EU’s sanctions.

The businessman, Igor Medved, is also reported to be preparing a guilty plea.

It is alleged that through his company, Nordwoc Limited, exports of sanctioned machinery have been made to Belarus. The precise type of machinery is not specified in the reports.

The investigation by the State Security Service was first made public in October 2023, at which time a freeze was also imposed on the shares of Nordwoc.

The prosecution is reported to be seeking a two-year custodial sentence, a fine of €225,000 and confiscation of €30,000 as well as confiscation of the shares of Nordwoc.

Poland – German national charged with exporting dual-use goods to Russia

It is being reported that Polish authorities have arrested and charged a German national with exporting dual-use technology to Russia in breach of EU sanctions.

The arrest was in the Lubusz province and relates to the export of machinery which can be used in weapons manufacture. It is also said that the exports were directed at “Russian military plants involved in weapons production”.

The individual is reported to have admitted his guilt.

The press release is here.

Latvia – update on current sanctions enforcement including 5 convictions in 2024

An article in Latvia’s LTV has provided an update on a number of features of Latvian sanctions enforcement.

Firstly, the Customs Administration stated that they had confirmed 2,623 breaches of sanctions so far this year up from 2,175 in 2023.

It was also stated that to date “€662,498.27 worth of goods have been confiscated in favor of the State in criminal proceedings for breach of sanctions”.

This is a substantially higher figure that those for confiscations identified in our recent post summarising Latvian convictions obtained in 2022 and 2023.

The article also stated that a total of 14 prosecutions had been brought in relation to the making available of economic resources to companies (i.e. the websites Sputnik and Baltnews) owned or controlled by Dmitry Kiselyov.

Two of those prosecutions ended in convictions in 2023 (as per our earlier post above), but the article adds that “This year [i.e. 2024], three more cases have ended in fines and community service”.

Lastly, the article adds that there have been two other convictions obtained during 2024, but that none of the 2024 judgments have yet entered into force.

Although not mentioned in the article, it has been confirmed to me by Paulis Iljenkovs of Latvia’s FIU (who has also consented to me sharing the information), that Latvia currently has 382 ongoing sanctions investigations.

United Kingdom – further charges against individual already facing prosecution for breaching Russian sanctions

As an addition to the existing prosecution it is being reported that the National Crime Agency has added two new charges to those against Alexei Owsjanikow. It is alleged that he paid £41,027.25 on behalf of his brother-in-law, designated person Dmitrii Ovsiannikov, towards private school fees.

The payments are said to have been made in May this year, which would be after Owsjanikow had already been charged with other sanctions offences.

The trial for this prosecution is currently scheduled for March 2025.

United Kingdom – HMRC drops investigation into alleged perfume exports to Russia

Further to our earlier post about an HMRC criminal investigation into the alleged export of luxury perfume to Russia, it is now being reported by the BBC that the investigation has been dropped.

The report does not explain the rationale for discontinuing the investigation, but notes the the primary individual involved, a Mr Crisp, had been recorded on video by a private investigator who asked “How’s your Russian market”, to which the recorded response was “We’re doing really well… we ignore government edicts”.

Another director of the company compiled evidence of the alleged sanction breaches, and provided that to the authorities.

That example of self-reporting and co-operation may well explain why the company was not itself prosecuted. It is unclear why the director Mr Crisp has not been pursued. The investigation first came to light after a civil court ruled there was “strong prima facie evidential basis for the allegations” and ordered the removal of Mr Crisp from his position as director of the company.

Latvia – details of the 10 Russian/Belarusian sanctions convictions from 2022 and 2023

With gratitude to a Paulis Iljenkovs of the Latvian FIU who pointed me to the website of Latvian anonymised case law, we can publish details of the criminal convictions to date under the EU’s Russian and Belarusian sanctions regimes.

As per an earlier post (here) it had been reported that there had been seven convictions to over 2022 and 2023. When including cases where companies and individuals were both convicted the correct figure is 10 convictions in 7 cases.

The website including Latvia case law is here. The case numbers provided below can be entered into the “Atlasīt pēc arhīva numura:” window to retrieve the judgments themselves which are in Latvian.

A. Case K77-3109-23. Riga City Court. 30 October 2023.

This case concerned the export of a Bentley Mulsanne Speed luxury vehicle to Russia that was sold for €112,552.69 in breach of the EU’s prohibitions on the export of luxury goods.

The company was convicted and fined €111,600 and had the full proceeds from the sale of the car confiscated as well.

The senior individual within the company was also convicted and personally fined €62,000.

In an earlier post we had reported that the total fine from this case was €170,000, but this sum excluded the confiscation.

B. Case K77-2464-23. Riga City Court. 25 October 2023.

The case was the prosecution of an individual who worked for Rossiya Segodnya, a Russian state media channel (the company is not named in the judgment, but is known from earlier press releases as per our earlier post).

The journalist was prosecuted for making “economic resources” available to a designated person, with Rossiya Segodnya having a designated person – Dmitry Kiselev – as its Director General.

The court held that the work product prepared during the course of employment constituted “economic resources” and that making these available to a designated person was a breach of the asset freeze imposed on Kiselev under the EU’s sanctions.

The fine was €6,820.

C. Case K77-2465-23. Riga City Court. 26 June 2023.

This case is twinned with Case B (K77-2464-23) above. The prosecution was of another journalist working for the same organisation, and the same case theory of the work product constituting “economic resources” was pursued.

In this instance, however, the journalist pleaded guilty and expressed remorse.

As part of a plea deal the individual was sentenced to 140 hours of community service.

The judgment itself concerned whether this plea deal was procedurally proper as a matter of Latvia law, and it was upheld.

D. Case K77-3055-23. Riga City Court. 17 October 2023.

This case was the prosecution of a company and individual for importing gas cylinders and valves from Belarus in breach of import prohibitions under the EU’s sanctions. The contract value was €73,508.

A senior person within the company, and the company itself were prosecuted and convicted.

The individual was fined €12,400.

The company was fined double that sum – €24,800, and had profits of €9,500 confiscated. This figure is not explained but may have been the profit made from on-selling the imported goods. The company was also banned from conducting any further business with Belarus for a year.

E. Case K12-0283-23. Daugavpils Court. 14 April 2023.

We have posted on this conviction previously.

The case concerned the conviction of an individual for importing 8kg of nails and 13 consignments of railway sleepers from Belarus in breach of the EU’s sanctions.

The man was fined €6,200 and barred from importing any goods from Belarus for a year.

A co-accused was also convicted (the judgment for which could not be found on the case law website) and was fined €5,000 and given a similar ban from importing any goods from Belarus for a year.

F. Case K77-1597-23. Riga City Court. 20 February 2023.

This case concerned the transfer of a professional football player from a Latvian club to a Belarussian club that was 79% owned by a designated person.

The transfer fee was US$50,000.

The player was treated in the judgment as an “economic resource” made available to a designated person in breach of the EU’s asset freeze.

The senior individual at the Latvian club pleaded guilty and was fined €6,200.

The club was also convicted and had the full US$50,000 transfer fee confiscated.

Romania – 23 companies fined for sanctions breaches imposed to date

The news website g4media in Romania has made a Freedom of Information request to Romania’s ANAF enforcement agency.

It has published an article summarising the results, and also provided the original response.

The response identifies the following enforcement statistics:

  • 23 companies fined for sanctions breaches to date (between 2020 and 2024);
  • 560,000 lei in fines (c. €112,000);
  • 41,492,169 lei confiscated as the proceeds of crime (c. €8,330,000);
  • 11 of the fined companies have appealed the fines imposed:
    • 4 of those appeals were won by ANAF;
    • the ANAF lost one;
    • 6 of the appeals are pending, although ANAF won 4 of those at first instance;
  • As part of this enforcement ANAF also undertook 7 audits of companies which were doing business with sanctioned entities and imposed fines of 65,575 lei (c. €13,100).

As per our earlier post, as of November 2022, Romania was reported to have imposed fines of 280,000 lei and confiscated 13,171,000 lei (c. €2,650,000). The balance of these further fines have been imposed since that date.

Germany – three individuals in custody for exporting nearly 100 cars to Russia in breach of sanctions

It is being reported that the Mannheim Public Prosecutor’s Office has three people in custody on suspicion of exporting luxury cars to Russia in breach of EU sanctions.

A car manufacturer made a suspicious activity report regarding the exporter, which led to the investigation.

The three individuals are a married couple who run two car dealerships and a third person who was an employee.

It is alleged that they exported nearly 100 cars to Russia via third countries with a total value of nearly €15 million.

As part of the raids, the prosecutors also secured the freezing of €1.3 million.

© 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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