This story is actually from September 2024, and was previously missed by this blog.
Three individuals were convicted of 430 separate violations of the German Foreign Trade Act by way of exports of nearly 500 luxury cars to Russia in breach of sanctions.
The individuals falsely declared the exports were for Belarus.
Two of the individuals were each sentenced to 6 years in jail, and the third to 4 years.
In addition €30m in the gross proceeds of the sales were confiscated.
With grateful thanks to the Ministry of Finance and the Economy in Poland for the provision of the information, this blog can provide an up-to-date summary of the scale of financial penalties imposed by the Polish authorities in relation to Russian and Belarusian sanctions violations.
These figures relate to the period up to 28 August 2025.
In total the Polish authorities have imposed 42 financial penalties, broken down on the following basis:
This updates the statistics previously published on this blog from July 2024.
It shows that Poland has imposed a 18 fines since that time. Of those 12 were under Regulation 833/2014, four were under Regulation 269/2014, and the two smaller fines relating to Belarus have also been imposed since July 2024.
The Dutch courts have published two sanctions judgments.
In the first case, the District court of Rotterdam has sentenced an individual to three years in jail.
The individual was convicted for providing technical assistance to a person in Russia or for use in Russia of different computer files containing information on the manufacture of microchips. The files were shares by Google Drive and Telegram between January 2023 and August 2024.
The defendant was acquitted of charges of physically taking similar files to Russia on USB sticks.
On sentencing the judgment stated:
“Providing advice to and sharing technology with Russia is extremely serious. It can contribute to strengthening military or strategic capabilities of that country, which has an impact on Ukraine and can indirectly affect international security and stability. It is therefore a serious offence. … The nature and seriousness of the facts justify a prison sentence of considerable duration. The fact that the files would contain outdated information is irrelevant because this information can be of great value to a country with a (much) lower level of knowledge. It must be prevented that a country at war can benefit in any way from advanced technological knowledge. After all, for that reason, an extensive package of sanctions has also been agreed against Russia, among others“.
In the second case, the District Court of Amsterdam has issued an order confiscating €1,013,956.00.
The unnamed corporate defendant had been provided goods and services in relation to the construction of the Kirch Bridge, and had been convicted on 28 November 2024 (our previous post here), with a fine of €120,000 imposed.
The court calculated that the gross revenue obtained in breach of sanctions was €2,711,085, but allowed certain costs including internal time incurred and the cost of insurance resulting in a final confiscation of €1,013,956.
The effect of this is that revenue of nearly €1.7m obtained in breach of the EU’s sanctions was retained by the convicted company.
It has been reported that the Spanish National Anti-Fraud Investigation Office, and competition authorities, have opened an investigation into the importation of diesel to Spain from Turkey and Morocco.
The suspicion being investigated is whether the diesel actually originates from Syria, Russia and/or Iran.
The investigation is reported to have been commenced in late 2024.
As further reported: “Several of the companies that were accused of bringing oil from Morocco due to their price advantage as they are of Russian origin in 2023 have either been disqualified or are currently involved in legal proceedings for fraud“.
Poland’s National Tax Administration yesterday issued a press release detailing raids and arrests in three provinces.
The three arrested individuals have been charged and are in pre-trial detention. They are suspected of importing birch plywood from Belarus and Russia in breach of EU sanctions.
The Tax Administration has conducted a number of similar investigations in recent months, which have not previously been included in this blog:
24 April 2025 – The Pomeranian branch of Poland’s National Tax Administration has conducted raids in Gdynia. Thirty pallets of timber suspected to have been imported from Belarus and Russia were seized.
9 April 2025 – The Pomeranian branch of Poland’s National Tax Administration has conducted inspections of timber purportedly imported from Tunisia at the Baltic Container Terminal in Gdansk, and seized over PLN 1 million in timber on suspicion that it was imported from Belarus and Russia in breach of EU sanctions.
28 February 2025 – The Lublin branch of the National Tax Administration has seized 1800 pallets of plywood suspected of being imported from Belarus and Russia via China and Kazakhstan. The press release adds that 15 sets of proceedings are being prepared as a result of the seizures valued at PLN 3.2m.
November 2024 – raids were conducted in seven provinces in relation to an ongoing investigation into suspected imports of timber from Belarus and Russia in breach of Eu sanctions.
The Financial Intelligence Unit of Latvia has published its Financial Integrity Newsletter for its activity during 2024.
This includes a range of sanctions enforcement-related statistics:
The Newsletter does not provide figures on the outcomes (to date) of the 392 criminal proceedings.
Further to the earlier post about Estonia having obtained 8 criminal convictions during 2024, we can publish details of the criminal convictions for breaches of the EU’s Russian sanctions that have been published on Estonia’s searchable gazette of published judgments.
As well as one conviction obtained in 2022, below we are publishing summaries of seven of the convictions from 2024 and three from 2025 (not including the conviction made public on 16 April 2025) as well as machine translations of the respective judgments.
The sentences range from fairly small monetary fines up to custodial sentences of 5 years in jail.
The offence was the attempt to export a 3D printer and an electromagnetic positioner. Mr Rafalovich was carrying false papers indicating the goods were destined for an Armenian company, as well as other papers indicating the true recipient to be a Russian company.
2. Judgment of 5 February 2024 – Victor Manilo was convicted and ordered to pay €2,680 as a fine.
The offence was the attempted export of €14,000 in physical currency to Russia.
3. Judgment of 14 February 2024 – Galina Sergejenkova was convicted and ordered to pay €3,960, such payment suspended for a probationary period of 18 months. A separate payment of costs and a penalty of €1,434.96 were to be paid straightaway.
The offences were two attempts to transport physical currency (of €900 and €1,000 respectively).
4. Judgment of 27 February 2024 – Evgeniy Kozlovtsev was convicted and given an eight month sentence suspended for a probationary period of 18 months. He was also ordered to pay a penalty and costs of €1,430.
The offence was the attempted export to Russia of two bottles of wine greater than the €300 luxury threshold. It was the man’s second attempt at such exports.
5. Judgment of 8 March 2024 – Aleksei Bond was convicted and given a five month prison sentence suspended for a probationary period of 18 months. He was also ordered to pay a penalty and costs of €1,555.
The offence was the attempted export of a luxury watch valued at €13,900 to Russia.
6. Judgment of 27 March 2024 – Lev Pylkin was convicted and ordered to pay a penalty of €1,190, as well as confiscation of the cash he attempted to export to Russia.
The offence was the attempted export of €2,560 in physical currency across the border to Russia. He had previously attempted to export cash at which time the details of the offence had been explained. The judgment is the dismissal of an appeal against the conviction and sentence.
7. Judgment of 17 October 2024 – Ruslan Sibilev was convicted and ordered to pay a fine of €79,557.50 as well as confiscation of a large number of rifle scopes, binoculars and other equipment.
The offences were committed through the acquisition of a range of sanctioned goods from a Portuguese company and an Austrian company, with Sibilev acting to coordinate further transport for the export of the goods to Russia. The orders were placed between May 2022 and April 2023. The total value of the goods ordered was nearly €1 million.
8. Judgment of 16 December 2024 – Oleg Osipov was convicted and sentenced to 8 months in prison suspended for a probationary period of 18 months. He was also ordered to pay €13,230, including 100% of the fee earned as part of the sanctioned transactions.
The offences were committed through Osipov providing a brokering service for the export of luxury goods to buyers in Russia between May and July 2023. The goods included electrical goods, phones, alcohol, navigation systems and various automotive parts. Osipov contracted with others to deliver the goods and took a brokering fee for arranging the transactions.
9. Judgment of 14 February 2025 – Demyan Belyakov was convicted and sentenced to 5 years in jail and ordered to pay €8,231 in costs and other penalties. In addition a large volume of goods were confiscated.
The offences were committed through the actual and attempted export to Russia of hundreds of silencers and firearm flash suppressors between February and June 2024.
10. Judgment of 20 February 2025 – Andrei Klychkov was convicted and sentenced to serve two months in prison plus a further period of 2 years and 10 months suspended for a probationary period of 4 years. €5,000 was also confiscated and he was ordered to pay costs of €2,581.
The offences were committed by the attempted export of parts for firearms, to Russia.
11. Judgment of 21 March 2025 – Aleksandr Ivantsov was convicted and sentenced to 4 years, 11 months and 27 days (after deducting 3 days of pre-trial detention) suspended for a probationary period of 5 years and other conditions including a requirement for prior permission to be away from his house for more than 15 days, and permission to leave Estonia. He was also ordered to pay €2,215 and had 70,550 rubles, and other goods, confiscated.
The offence was committed by the attempted export of six pairs of night-vision binoculars.
This case is related to that above for Ruslan Sibilev with Mr Ivantsov being one of the people used to try and physically carry the goods across the border into Russia.
OFSI has published its annual report for the year 2023/2024.
The report provides the following data:
2021/22 – 147 investigations opened (and 101 closed);
2022/23 – 473 investigations opened (and 74 closed); and
2023/24 – 396 investigations opened (and 242 closed).
Of the 396 investigations opened in 2023/24, 288 were as a result of self-reporting with 108 opened through pro-active investigation or other means.
Further, OFSI’s report gives a break down of which sanctions regimes the investigations relate to:
The report also gives a break down of the 242 investigations closed during the year of the report:
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.
It is being reported that on 16 January raids were carried out at six addresses 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.
The Customs press release is here.
