2024 – Page 9 – European Sanctions Enforcement

August 23, 2024 by Mark Handley

United Kingdom – 12 oil price cap investigations by OFSI

It is being reported (here albeit behind a paywall), that as of April 2024 the UK’s Office of Financial Sanctions Implementation (OFSI) had twelve ongoing investigations relating to possible breaches of the oil price cap imposed as part of the UK’s sanctions against Russia.

The information comes from a Freedom of Information Act request made by the publication Trade Winds. The response is not available on OFSI’s website.

OFSI is also reported to have confirmed that 9 of the twelve investigations were discontinued in April 2024 with no further action taken.

No information was provided on the current status of the other three investigations that were live in April, or whether any further investigations have been commenced since April.

As noted in our previous post from May, at that stage HM Treasury had stated that it “a number of investigations” then ongoing into alleged oil price cap breaches.

August 16, 2024 by Mark Handley

Lithuania – company fined over €1.2m for importing Russian coal and rubber from designated persons

The Customs Office of Lithuania has issued a press release confirming that it has imposed a fine of €1,274,960 on an unnamed Lithuanian company for the importation of both coal and rubber from Russia in breach of EU sanctions.

The Russian suppliers are themselves said to be the subject of sanctions, but have not been named.

The enforcement action was conducted by the Business Entity Inspections Department of the Kaunas Region.

August 14, 2024 by Mark Handley

Lithuania – more than 50 currently-ongoing sanctions investigations

A published interview with Lithuania’s Prosecutor General has stated that the Lithuanian authorities currently have “more than 50 pre-trial investigations into sanctions violations” – including both Russian and Belarusian sanctions.

The interview included mention of the fact that one of the investigations relates to suspected arms smuggling, and that this has been referred to the court for prosecution.

The same article reported on a press release from Lithuania’s Financial Crime Investigation Service of yesterday, which stated that seven individuals and four companies are suspected of unlawful exports to Russia valued at nearly €2 million. Searches of 18 different premises have been conducted as part of this investigation.

It is alleged that attempts were made to mask the unlawful exports with false declarations naming different goods, as well as false destinations for the exports to Turkey, Kazakhstan, Uzbekistan, Belarus.

Details of the other ongoing investigations were not provided.

August 14, 2024 by Mark Handley

Switzerland – investigation into suspected breaches of Russian asset freeze

It is being reported that the Office of the Attorney General in Switzerland has opened criminal and administrative proceedings as part of investigations into suspected breaches of the asset freeze imposed on Suleyman Kerimov under Swiss sanctions.

It is being reported that SECO has confirmed that the criminal proceedings were commenced in November 2023 and that four individuals are under suspicion, as well as that eight premises have been raided so far.

Assets worth SWF 1.3 billion have also been made subject to a “super-provisional” asset freeze.

August 14, 2024 by Mark Handley

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.

August 14, 2024 by Mark Handley

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.

August 12, 2024 by Mark Handley

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.

August 7, 2024March 10, 2026 by Mark Handley

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 more detail on these other enforcements was provided.

July 31, 2024 by Mark Handley

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.

July 31, 2024 by Mark Handley

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.