Estonia – 83 criminal prosecutions for Russian trade sanctions violations since 2024

It has been reported that during 2024 Estonia’s Internal Security Service commenced 71 criminal cases in relation to suspected trade with Russia in breach of the EU’s sanctions, and has commenced another 12 already during 2025. These cases are said to be for the more serious, intentional or repeat offenders.

The same report note that Estonia’s Police and Border Guard Board are currently identifying an average of 12 sanctions violations per day predominantly by individuals attempted to take cash or luxury goods into Russia. This is reported to be down from a previous average of 22 violations per day.

With all people crossing the border being subject to inspection, first time offenders are required to either turn back and not cross, or to accept confiscation of the goods/items and continue the journey.

Germany – raids and arrests of suspected exporters of luxury cars to Russia and Belarus

It is being reported that on 16 January raids were carried out at six addressed in Ludwigshafen, Schifferstadt and Mannheim and a 53-year old was arrested on suspicion of exporting over 150 luxury cars to Russia and Belarus valued at more than €7,500,000.

Cash and cars valued at more than €500,000 were seized and accounts frozen.

The same article reports on another case from November 2024 (also reported here), in which a 26-year old was arrested and detained on suspicion of exporting 30 luxury cars to Russia valued at around €3,500,000.

Finland – sanctions investigation closed into returned Russian art

In April 2022 Finnish Customs seized over 200 pieces of art being shipped back to Russian museums such as the State Hermitage Museum and the Tretyakov Gallery.

It is now being reported that at that time an investigation was commenced by Finnish Customs working with the Finnish Foreign Ministry as to whether permitting the onward transit of the objects and artefacts, or the shipments themselves, would amount to breaching EU sanctions.

The artefacts were later allowed to travel on to Russia while the investigation continued.

As of 24 December 2024, it is now being reported (in the linked article above) that the investigation has concluded with no further action to be taken.

Bermuda – trust company fined $600,000 for sanctions and AML compliance failings

On 30 December the Bermuda Monetary Authority announced the imposition of a fine of $600,000 on Meritus Trust Company Limited for a series of AML and sanctions compliance failings.

In terms of sanctions compliance the failing was specified as “An overreliance on manual processes to implement international sanctions policies and procedures and sanctions screening“.

The BMA’s on-site investigation was commenced in June 2022 and the company was then given a deadline of July 2023 to complete the necessary remediation. The BMA was satisfied with the company’s efforts and noted a number of mitigating factors such as a low risk of loss to clients, co-operation, the remediation efforts, and the company’s overall culture of compliance.

This is a rare example of a sanctions enforcement fine being imposed in one of the UK’s overseas territories or crown dependencies. The only other example known (to this blog) are the fines and other punishments imposed in Guernsey in 2015/2016.

Latvia – more than 100 criminal cases for sanctions breaches commenced during 2024

It has been reported that the Latvian authorities commenced 100 criminal cases for suspected sanctions violations during 2024.

In late October 2024 the figure was reported as 94, meaning that the final weeks of the year continued to see new criminal cases started.

The cases appear to be predominantly related to breaches of trade sanctions and the reporting states that the prohibited products included “engines, steel products and optical devices”.

Estonia – person detained for alleged breach of designated person’s asset freeze

It is being reported that the Estonian authorities have arrested and detained a 65-year old named only as Tatjana, for allegedly managing and handling funds on behalf of the Foundation for the Support and Protection of the Rights of Russian Compatriots Living Abroad, which is a designated person under the EU’s sanctions.

It is alleged that Tatjana received €50,000 from the Foundation and used the money to fund a person’s defence in an ongoing criminal trial in Estonia.

Estonia – police and border guards conduct over 240 inspections of Russian “shadow fleet” vessels

It has been reported that Estonia’s police and border guards have between them conducted over 240 inspections of vessels in waters of Estonia’s economic zone in the last 6 months. Estonia adopted the policy of conducting inspections in June of this year.

The vessels are said to belong to Russia’s so-called “shadow fleet” and the inspections relate to verifying compliance with requirements such as valid insurance.

United Kingdom – company convicted of export control violations

His Majesty’s Revenue and Customs (HMRC) has announced the conviction of the company EDM Limited on three counts of exporting controlled military goods without the appropriate licence.

The good in question were military flight simulators valued at £38,967.68.

The company was fined £89,359.80, including costs, but HMRC’s Notice does not mention whether a confiscation order was also made.

EDM Limited had been offered a civil compound penalty to resolve the matter but had not accepted the offer in time and so the case went to trial.

Netherlands – third defendant found guilty in sanctioned aircraft parts export prosecution

Further to our earlier posts from 8 October and 7 October relating to the conviction of a company and individual for exporting aircraft parts to Russia in breach of EU sanctions, the Rotterdam District Court ruled on 22 November that the third co-defendant is also guilty.

The judgment is here.

The individual was an employee of the Ministry of Defence and was first arrested in September 2023 (see our earlier post).

The conviction was based on the export of parts via Tajikistan, Kyrgyzstan, Turkey the UAE and Serbia. The Defendant was also convicted of falsifying documents and of a minor fire arms charge.

The court accepted findings of PTSD by court psychologists and the probation service.

At sentencing the court stated: “In view of the seriousness of the proven facts, from the point of view of general prevention, a prison sentence of considerable duration is in principle appropriate“.

In the circumstances of the defendant, however, the custodial sentence was limited to the period of pre-trial detention with a further period of 195 days suspended for two years. In addition 240 hours of community service was imposed.

The individual was also disqualified from acting as a company director for three years.

© 2009-2025 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.

Proudly powered by WordPress