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.
On 4 November 2024, HMRC published a Notice to Exporters regarding a compound penalty of £58,426.45 imposed for breaches of Russian trade sanctions.
The Notice included the line:
“Since February 2022, HMRC has issued six compound settlements against UK companies that have breached the Russia sanctions regulations for a total of £1,363,129, including one in August 2023 for £1 million“.
This struck a chord because, as captured in this blog, only three compound penalties had been publicly imposed by HMRC for breaching Russian sanctions. So a Freedom of Information request was made about the other three.
The response is here.
The response discloses details of three compound penalties (totalling c. £237,000) from August and September 2022 and April 2023. These had each been previously published, but had not previously been described as relating to Russian sanctions.
It is unclear why these penalties were not previously described as relating to breaches of Russian sanctions.
The FOIA request also asked for the names of the individuals or companies which were the subject of the penalties; whether any had self-reported; and what (if any) confiscation of the proceeds of crime was applied. These questions were not answered.
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.
Presenting a webinar this morning made me aware that this blog had missed a number of stories relating to Danish sanctions enforcement.
I have endeavoured to rectify that gap with a number of posts filling gaps from 2022 through to early 2024. Because I have back-dated the posts so that they appear in the correct sequence it made sense to collect them into a properly new post to highlight the additions.
Importantly, between February 2022 and August 2023 a total of 98 investigations were opened, with 16 referred to the police. In addition the police have charged a company and two individuals in relation to one particular case.
It is being reported that the Czech authorities have an unspecified number of ongoing investigations into Czech companies suspected of circumventing the EU’s Russian sanctions.
As per our earlier post from June 2023, it was then reported that Czechia had 40 ongoing investigations.
It is being reported that a German customs investigation has been commenced into the business affairs Jörg Dornau who is an MP in the Saxon state parliament.
It is alleged that he arranged for the export of machinery to Belarus in breach of EU trade sanctions.
It is alleged that the goods were first sent to Kazakhstan before then being on-shipped to a company in which the politician has interests in Belarus called Zybulka-Bel.
The press article mentions that before any prosecution could be brought the MP’s immunity would need to first be lifted.
It is being reported that a Belarusian businessman resident in Latvia is being prosecuted for alleged exports to Belarus in breach of the EU’s sanctions.
The businessman, Igor Medved, is also reported to be preparing a guilty plea.
It is alleged that through his company, Nordwoc Limited, exports of sanctioned machinery have been made to Belarus. The precise type of machinery is not specified in the reports.
The investigation by the State Security Service was first made public in October 2023, at which time a freeze was also imposed on the shares of Nordwoc.
The prosecution is reported to be seeking a two-year custodial sentence, a fine of €225,000 and confiscation of €30,000 as well as confiscation of the shares of Nordwoc.
It is being reported that Polish authorities have arrested and charged a German national with exporting dual-use technology to Russia in breach of EU sanctions.
The arrest was in the Lubusz province and relates to the export of machinery which can be used in weapons manufacture. It is also said that the exports were directed at “Russian military plants involved in weapons production”.
The individual is reported to have admitted his guilt.
An article in Latvia’s LTV has provided an update on a number of features of Latvian sanctions enforcement.
Firstly, the Customs Administration stated that they had confirmed 2,623 breaches of sanctions so far this year up from 2,175 in 2023.
It was also stated that to date “€662,498.27 worth of goods have been confiscated in favor of the State in criminal proceedings for breach of sanctions”.
This is a substantially higher figure that those for confiscations identified in our recent post summarising Latvian convictions obtained in 2022 and 2023.
The article also stated that a total of 14 prosecutions had been brought in relation to the making available of economic resources to companies (i.e. the websites Sputnik and Baltnews) owned or controlled by Dmitry Kiselyov.
Two of those prosecutions ended in convictions in 2023 (as per our earlier post above), but the article adds that “This year [i.e. 2024], three more cases have ended in fines and community service”.
Lastly, the article adds that there have been two other convictions obtained during 2024, but that none of the 2024 judgments have yet entered into force.
Although not mentioned in the article, it has been confirmed to me by Paulis Iljenkovs of Latvia’s FIU (who has also consented to me sharing the information), that Latvia currently has 382 ongoing sanctions investigations.
As an addition to the existing prosecution it is being reported that the National Crime Agency has added two new charges to those against Alexei Owsjanikow. It is alleged that he paid £41,027.25 on behalf of his brother-in-law, designated person Dmitrii Ovsiannikov, towards private school fees.
The payments are said to have been made in May this year, which would be after Owsjanikow had already been charged with other sanctions offences.
The trial for this prosecution is currently scheduled for March 2025.
