Austrian military goods enforcement (2008-2017)

The Austrian Ministry of Justice has published statistics showing its enforcement between 2008 and 2017 of the Austrian “War Materials Law”.

Year Investigations Prosecutions Penalty Notices Convictions


2 0




2 0




6 0




4 0




3 2




7 1




5 1




5 2




7 0




9 1


Netherlands – criminal fine imposed for breach of Russian sanctions

The Dutch Public Prosecution Service has obtained a criminal fine of €50,000 against an unnamed Dutch freight solutions company.

The company had sought to ship radar equipment for Sukhoi jet fighters from Malaysia to Russia. The consignment was intercepted at Schiphol Airport. The sale was in breach of both European export controls, as the products were included on the EU’s Military List, and in breach of Russian sanctions which would have prohibited the granting of an export licence.

No licence had been applied for.

An individual was acquitted of a related offence.

Netherlands – fine of €100,000 imposed on payment services provider

In 2015 the Dutch National Bank had imposed a financial penalty of €125,000 on an unnamed payment services provider for failings in relation to sanctions and PEP screening as part of a review by the bank.

The payment services provider appealed the decision.

On appeal to the District Court of Rotterdam the penalty was upheld but the fine reduced to €100,000.

The National Bank had originally calculated the fine as €550,000 which was then reduced due to the financial condition and size of the defendant.

Germany – Iran sanctions prosecution case sent to Federal Court

A prosecution in relation to the export of valves for use in the Iranian nuclear sector which has been ongoing since 2014 has now been referred to the German Federal Court.

The prosecution of three individuals, named only as Bernd Gehrad L., René L. and Ralf C, relates to the export of 51 specialized valves to Iran between 2010 and 2011. The value of the valves was approximately €1 million.

The case has been sent to the Federal Court after a court in Berlin had ruled that the penalties being sought were unconstitutional.

Netherlands – investigation into alleged breach of Crimean sanctions

It has been reported that the Dutch International Development minister has ordered an investigation into the alleged involvement of two Dutch companies, Dematec Equipment and Biljard Hydrauliek, in providing equipment for the building of the Kerch Strait Bridge designed to join Russia and Crimea.

The allegations, if proven, would be a breach of the EU’s Crimean sanctions.

Netherlands – fine and custodial sentence imposed for breach of Iran sanctions.

The District Court of East Brabant has convicted an individual for breaches of the EU’s Iran sanctions.

The defendant had traded for 2 years with a designated Iranian entity. The unspecified goods had been shipped via intermediary countries Turkey and Dubai.

He was sentenced to 16 months in jail, with a further 4 months suspended subject to a two-year probation period. He was also fined €500,000. The fine was on the individual personally and not on the company through which he traded.


Lithuania – prosecutors commence investigation into possible Crimean sanctions breaches

The Lithuanian Prosecutor General’s Office has announced that the Lithuanian Financial Crime Investigation Service has opened an investigation into alleged breaches of the EU’s Crimean sanctions by three different enterprises:

a) two Lithuanian companies: BT Invest, and Hanner Group OÜ; and

b) one Crimean company owned by a Lithuanian: Pluošto Linija LLC.

It is understood that the allegation relate to investments and business dealings by Lithuanian nationals in Crimean companies and property developments in breach of the EU’s sanctions against Crimea.

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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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