Germany – raids in Berlin as part of sanctions investigations

It is being reported (and here) that on Tuesday the Zentralstelle für Sanktionsdurchsetzung (Central Office for Sanctions Enforcement) conducted raids with 100 officers to enforce a District Court judgment  on premises in the Tempelhof-Schöneberg region of Berlin.

The reports also state that the subjects of the raids were two logistics companies, said to be from Russia.

No details of the alleged conduct or Russian sanctions breaches giving rise to the raids has been released.

European Public Prosecutor’s Office conducts Russian sanctions-related raid in Bulgaria

It is being reported (here and here) that the European Public Prosecutor’s Office has conducted a raid on the premises of Bulgartransgaz in Bulgaria.

The investigation is said to concern whether natural gas supplied via the Turkish company Botas may include gas of Russian origin and be being done in circumvention of the EU’s Russian sanctions.

This would be the first public and specific investigation by the European Public Prosecutor’s Office into allegation of sanctions breaches.

Cyprus – Russian-German national extradited to the US

A press release from the United State’s Attorney’s Office for the Southern District of New York has included details of an arrest and extradition by the Cypriot authorities in support of US charges of sanctions and export control violations.

On 26 August 223, Arthur Petrov was arrested in Cyprus in relation to:

“export control violations, smuggling, wire fraud, and money laundering offenses in connection with his alleged participation in a scheme to procure U.S.-sourced microelectronics subject to U.S. export controls on behalf of a Russia-based supplier of critical electronics components for manufacturers supplying weaponry and other equipment to the Russian military”.

Mr Petrov operated the scheme through his Cypriot company Astrafteros Technokosmos LTD.

His extradition from Cyprus was completed and he arrived in the US on 8 August 2024.

Lithuania – company fined €13.6m for sanctioned exports to Russia

The Lithuanian Customs Service has issued a press release regarding a fine of €13,618,175 imposed on a company.

The company had exported vehicles to Russia through third countries Belarus, Kazakhstan and Turkey.

Six tractor semi-trailers were also confiscated.

Although the Customs press release does not name the company, press reports have identified the company as Biovarda based in Vilnius.

The press release also states, opaquely, that “After the Lithuanian customs started to apply stricter inspection measures, it is not the first time that such sanctions have been applied to companies for violations of the Law on International Sanctions”. No ore detail on these other enforcements was provided.

UK – investigation by HMRC into potential Airbus violations of export controls

Reuters has reported that Airbus’s most recent half-yearly financial statements include reference to an ongoing investigation by HMRC.

Under the heading “HMRC Export Control Investigation”, the financial company records: “Airbus is fully cooperating with an investigation by the Revenue and Customs Authority of the United Kingdom into possible violations of the United Kingdom’s export control rules. It is not expected that the resolution of this matter will have a material financial impact“.

No further details are provided.

Luxembourg – Financial Crime Unit’s report of sanctions investigations

Luxembourg’s Financial Intelligence Unit (the CRF) has published its Annual Report which includes statistics on sanctions-related SARS and investigations, as well as an indication of funds frozen as part of these investigations.

    • 160 instances of suspicion of breaches of sanctions reported since 24 February 2022:
      • 23 were in 2022;
      • 100 were in 2023; and
      • 36 so far in 2024
    • 15 information requests have been sent out by the CRF in relation to possible sanctions evasion:
      • 2 in 2022;
      • 13 in 2023; and
      • no indication of the number sent so far in 2024.
    • the CRF has also blocked €45,958,887.91 in relation to two suspected cases of sanctions evasion. No further details were provided.

UK – confiscation of more than £750,000 from family and estate of Petr Aven

It is being reported that the UK’s National Crime Agency has completed the confiscation of funds related to Petr Aven.

The sum of £750,000 was confiscated from bank accounts held in the name of Petr Aven’s wife and others.

A sum of cash initially recovered by the NCA from a residence outside London was also confiscated.

The funds were confiscated under the Proceeds of Crime Act 2002.

Updated on 1 August to reflect issuance of NCA’s press release:

The NCA has stated that the funds, totalling £783,827.34 were held for the benefit of Petr Aven although not in his name, and that the breaches of sanctions giving rise to the funds being the proceeds of crime were: “Attempts to relocate the funds, as well as transactions made after March 15 2022 by Aven’s estate manager, Stephen Gater … . These included the payment of salaries to over 20 members of Aven’s household staff, and the sale of a Bentley Bentayga worth £160,000“.

UK – extradition to the US for person suspected of Iran sanctions breaches

A press release from the  US Department of Justice records that an individual, Saeid Haji Agha Mousaei, was arrested in the UK on 24 January 2023 pursuant to an Interpol diffusion notice.

Mr Mousaei was then subsequently extradited to the US where he faces multiple charges arising from the alleged supply of “controlled electronics with military applications, including signals equipment like oscilloscopes and spectrum analyzers, for export and re-export to Iran”.

It is alleged that false documentation was prepared which indicated that the goods were to remain in countries such as the UAE and Armenia, but the goods were all transshipped to Iran via the UAE.

UK – two law firms reported to OFSI by legal regulator

It is being reported that two law firms have been reported by the Solicitors Regulation Authority (SRA) to the UK’s OFSI.

it is alleged that the law firms were facilitating financial transactions valued at more than £300,000. It is unclear whether the conduct relates to designated persons, trade sanctions, or the UK’s prohibitions on Russian investment.

The attention on law firms chimes with the report yesterday that there has been an investigation in Germany relating to a potential breach of the EU’s prohibitions on legal advice.

 

Poland – investigation and charge in relation to dual-use exports to Iran

It is being reported by Reuters that the Polish state-owned company WSK Poznan is being investigated by the National Prosecutor’s Office and the Internal Security Agency on suspicion of supplying parts to Iranian manufacturer, Motorsazan Company, which were then incorporated into drones used by Russian combat forces in Ukraine.

The National Prosecutor’s Office is also reported to have charged the CEO of the company in relation to the export of dual-use goods.

Another report states that the investigation has been ongoing for two years, and notes that the Polish National Prosecutor has denied evidence that parts were used for drones and stated that the investigation relates more to the sale of fuel pumps to Iran.

 

© 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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