Author: Mark Handley

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Posted on by Mark Handley

Latvia – 94 criminal proceedings commenced this year for Russia/Belarus sanctions breaches

In a reported interview with Raimonds Zukuls, the Deputy Director General of Latvia’s State Revenue Service, details of ongoing enforcement activity in Latvia have been provided.

These figures are specific to the EU’s sanctions against Russia and Belarus and include:

  • 94 criminal proceedings commenced during 2024;
  • more than 300 criminal proceedings overall (nb. as per our earlier post, the figure was 310 back in February 2024);
  • 2170 instances of blocked exports/imports during 2023; and
  • more than 2400 instances of blocked imports/exports during 2024.

Zukuls is also quoted as saying that the most frequent blocked exports to Russia and Belarus were cars, tractors, electrical equipment and appliances, and the most frequent blocked imports from Russia and Belarus were wooden products, animal feed and metal products.

Posted on by Mark Handley

European Sanctions Enforcement – performance league tables (2017-2024)

The figures are, naturally, based on publicly-available information as collated in this blog.

The figures are not always easy to reconcile into a coherent picture. For example:

  • The Netherlands has the most convictions, but none of the longest sentences;
  • Germany has far fewer convictions than the Netherlands, but all of the longest sentences;
  • Finland has a massive number of ongoing investigations but has only imposed fines to date of €11,080;
  • Switzerland has 15 convictions, but no custodial sentences and €58,435 in fines;
  • Poland has the highest number of successfully-concluded enforcement actions under the Russian sanctions but has no criminal convictions; and
  • The UK dominates the figures on total fines, but has a low number of criminal convictions.

Most criminal convictions since 2017:

  1. Netherlands – 40
  2. Switzerland – 15
  3. Germany – 10
  4. Latvia – 7

Fewest criminal convictions since 2017:

  1. Austria, Bulgaria, Croatia, Cyprus, Estonia, France, Greece, Hungary, Ireland, Lithuania, Luxembourg, Malta, Moldova, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden – 0
  2. Czechia and Norway – 1
  3. Denmark, Italy and United Kingdom – 3

Most Russian/Belarusian sanctions convictions/fines/penalties since 2017:

  1. Poland – 24
  2. Netherlands – 21
  3. Switzerland – 15
  4. Latvia – 11

Fewest Russian/Belarusian sanctions convictions/fines/penalties since 2017:*

  1. Belgium, Bulgaria, Croatia, Cyprus, Denmark, France, Greece, Hungary, Ireland, Luxembourg, Malta, Moldova, Portugal, Slovakia, Slovenia, Spain, Sweden – 0
  2. Czechia, Italy, Norway, Romania – 1
  3. Finland – 4
  4. United Kingdom and Lithuania – 7

* The Estonia figure is uncertain based on this story, but how high/low is uncertain.

Most currently-ongoing investigations:*

  1. Finland – 800
  2. Latvia – 310
  3. United Kingdom – 307
  4. Netherlands – 192

* Germany probably belongs on this list. It has commenced at least 1988 investigations since February 2022, but many of the States that responded to Freedom of Information Requests did not provide data on ongoing investigations, but only the total number of investigations commenced since the start of the full-scale war.

Longest custodial sentences since 2017 (where the sanctions element can be distinguished):*

  1. Germany – 7 years (2020)
  2. Germany – 6 years and 9 months (2024)
  3. Germany – 5 years (2023)
  4. Germany – 3 years and 9 months (2021)

* The list excludes convictions where there are also non-sanctions offences and where the sentence cannot be divided, such as the 19-year sentence imposed in the Netherlands which included war crimes offences.

Most extraditions to the United States to face US sanctions charges

  1. Latvia – 4
  2. Cyprus, Estonia, Spain, United Kingdom – 2
  3. Croatia, Germany, Greece, Italy, Romania – 1
  4. All other European countries are at zero.

Highest total value of fines/confiscations/penalties (in Euros) since 2017:

  1. United Kingdom – €268,344,548 (of which the FCA’s fines make up €228,465,751)
  2. France – €50,600,000
  3. Germany – €26,112,903
  4. Lithuania – €23,513,079

Lowest total value of fines/confiscations/penalties (in Euros) since 2017 where value is known:*

  1. Bulgaria, Croatia, Cyprus, Greece, Hungary, Ireland, Moldova, Portugal, Slovakia, Slovenia, Spain and Sweden – €0
  2. Norway – €4260**
  3. Finland – €11,080
  4. Switzerland – €58,435
  5. Czechia – €143,500

* Malta has imposed a fine of unknown size but greater than €800, and Austria has imposed at least 10 fines of unknown value.

** This is an underestimate for Norway as it has concluded 23 confiscations of goods where no value was published.

Highest single fines/confiscations/penalties within 2024

  1. UK – £29m by the FCA
  2. Lithuania – €13.6m by Customs
  3. Lithuania – €8.23m by the Financial Crimes Investigation Service
  4. Poland – €2.78m by Customs

Most successfully-concluded enforcements within 2024

  1. Poland – 22
  2. Netherlands – 10
  3. Lithuania – 7
  4. Switzerland – 6
  5. UK – 5*
  6. Germany – 4
  7. Luxembourg – 3
  8. Estonia – 2**
  9. Finland – 2
  10. Latvia – 2
  11. Czechia – 1
  12. Malta – 1
  13. All other European countries are at zero.

* The UK figure excludes export control enforcements unrelated to sanctions.

** The Estonia figure is likely to be higher based on this story, but how much higher is uncertain.

Posted on by Mark Handley

Netherlands – sanctions compliance fine on trust services provider upheld

The Rotterdam District Court has largely upheld a fine of €95,000 imposed on a trust services provider by the Dutch National Bank.

The DNB’s investigation started in 2019, and the fine was originally imposed on 2022.

The fine related to compliance failings including both money laundering and sanctions failures. The firm’s policies and procedures were insufficient and there was a lack of proper identification of the UBO and of ongoing diligence.

On appeal the fine was reduced to €90,250 due to an argument that the investigation process had been unduly lengthy,

Posted on by Mark Handley

Finland – Customs has more than 800 sanctions investigations

Finnish Customs has given an update on trade sanctions enforcement in Finland. The press release confirms that there are more than 800 such investigations being undertaken by Finnish Customs of which around 90 are being investigated as aggravated offences.

Oddly, a press report, published on the same day, reported that Finnish Customs had more than 740 ongoing investigations. The figure of 740 had been reported back in April, as per our earlier post, itself an increase on the figure of 700 investigations reported in February.

The press release from Finnish Customs also gave detail of a particular investigation into a customs warehouse company in eastern Finland suspected of exporting drones, processors, smartphones, computers and echo sounders to Russia.

The goods arrived in Finland as air freight at Helsinki Airport, after which they were attempted to be exported via the company’s intermediate storage in Virolahti by road to Russia.

The value of the sanctioned goods was about €700 000 and are said to have mostly been ordered from online stores in the US with the consignee in Russia as the Russian postal service.

To date seven people have been questioned as part of the investigation.

Posted on by Mark Handley

Norway – 37 ongoing Russian sanctions investigations

It is being reported that Norway’s Politiets Sikkerhetstjeneste (Norwegian Customs), has 37 ongoing investigations in relation to alleged breaches of Norway’s Russian sanctions. Many of these are said to involve attempts to evade detection by exporting to Russia via third countries, but some are described as relating to imports into Norway.

It is also being reported that there is a further investigation under Norway’s Export Control Act.

Posted on by Mark Handley

France – prosecution of Lafarge for ISIS sanctions breaches to go to trial

Further to our earlier post from February 2024, it is being reported that the Paris Court has ordered that the prosecution of the French cement maker Lafarge and eight individuals on charges of terrorist financing and breach of EU sanctions against ISIS should proceed to trial.

The case is part of a long running saga arising from allegations that the company paid money to ISIS in order to keep a cement plant open and operating.

Posted on by Mark Handley

Spain – four arrested and sanctioned cargo seized in OLAF-assisted investigation

OLAF – the European anti-fraud agency – has issued a press release setting out the assistance it has given to Spain’s National Police. The assistance appears to have been largely on the intelligence and analysis side.

As stated in the press release:

“As part of the investigation, the Spanish National Police and Customs Surveillance Service arrested four individuals in the Spanish region of Catalonia, three of whom are Russian nationals. The operation also resulted in the seizure of 13,000 kilograms of a chemical compound subject to export restrictions, at the Port of Barcelona.

The investigation revealed that a Spanish company, managed by Russian nationals, had established a sophisticated logistical and economic scheme to export internationally sanctioned chemical products to Russia. This network involved the use of shell companies in Armenia and Kyrgyzstan to disguise the true destination of the goods, which were later rerouted to Russia”.

The Police have also issued a press release, stating that the arrests were in the Catalan towns of Sant Feliu de Guisols (Girona), Cerdanyola del Vallès and Santa Perpètua de Mogoda (Barcelona), and that the operation included searches at residential properties.

This is the first announced enforcement of EU sanctions in Spain since April 2023.

This is also the first announced operation said to have been aided by intelligence-gathering by OLAF.

Posted on by Mark Handley

Cyprus – extradition of individual to face US sanctions charges

The US Attorney for the Southern District of New York has issued a press release, providing details of the arrest in Cyprus of Arthur Petrov a Russian-German national in August 2023 for the purposes of extradition to face charges in the US of breaching US sanctions against Russia.

Petrov only arrived in New York in August 2024 suggesting prolonged extradition proceedings in Cyprus.

Petrov operated the Cypriot company Astrafteros Technokosmos LTD, via which he procured US-origin microelectronics for onward sale, ultimately, to the Russian military through the company LLC Electrocom VPK.

Two other co-defendants remain at large.

Posted on by Mark Handley

Finland – three Russian nationals under investigation for dual-use exports

Further to our earlier post from May when three Russian national university students were arrested in Finland, an update on the case has now been reported.

The investigation of all three individuals continues, with two having been released from custody over the summer and the third recently released.

The conditions of bail include a travel ban, and it is said that the three are being investigated in relation to the “gross regulatory crime” of exporting dual use goods from Finland to Russia in breach of EU sanctions.

It is unclear whether this case is related to Tampere University recently reporting itself to the Finnish police.

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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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