Poland – multiple raids and arrests for suspected import of timber in breach of Russia and Belarus sanctions

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.

Germany – CJEU decision on sanctions conviction for exporting cash to Russia

The Court of Justice has issued a preliminary ruling arising from the criminal conviction in Germany of an individual who was stopped at Frankfurt Airport in May 2022 attempting to export €13,800 in cash to Russia.

The individual’s argument was that the funds fell within the “personal use” exception in article 5i(2)(a) of regulation 833/2014, as they were for intended for various medical procedures including dental treatment, fertility treatment and plastic surgery.

The Court of Justice has decided that a “strict interpretation of th[e] exception” was appropriate, that medical treatments do not fall within the exception, and that the exception was for “cash necessary to obtain essential goods and services in order to meet their needs during their travel and stay in Russia”.

The reference to the CJEU was from the Oberlandesgericht Frankfurt am Main, which was hearing an appeal from the original conviction.

Lithuania – OLAF and Lithuanian Customs raid company suspected of sanctions breaches

The European Anti-Fraud Office (OLAF) has issued a press release reporting on a joint operation with Lithuanian Customs.

After a joint investigation officers from both bodies took part in a raid in the Vilnius region.

The investigated conduct is said to involve the shipment of sanctioned goods to Russia through Central Asian countries. According to the Lithuanian Customs press release, the raised company was said to be providing “transport, logistics and forwarding services”.

Sanctioned goods valued at approximately €1.5 million, weapons and cash were seized as part of the raid. Four individuals were arrested as part of the raid.

Latvia – updated sanctions enforcement statistics

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:

  • 451 suspicious activity reports in relation to suspected sanctions breaches;
  • attempted cash exports to Russia of €18.9 million stopped;
  • more than 8,500 shipments across Latvia’s border with Russia stopped, of which 89% were exports and 11% were imports; and
  • 392 criminal proceedings started between 2022 and the end of 2024.

The Newsletter does not provide figures on the outcomes (to date) of the 392 criminal proceedings.

Estonia – details of eleven Russian sanctions convictions

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.

  1. Judgment of 10 October 2022 – Petr Rafalovich (a Belarus national) was convicted and given a two month sentence following which he was to be deported to Belarus and given a five-year ban from re-entering Estonia. He was also ordered to pay a penalty and costs of €1,250.40.

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.

Netherlands – timber confiscations from companies already under investigation for alleged sanctions violations

As reported in our post from June 2024, at that time the Dutch FIOD conducted raids and arrested two individuals suspected of importing Russian-origin timber in breach of the EU’s sanctions.

FIOD has now announced a further round of seizures from the same companies. The allegation is that the companies have continued to trade in Russian timber during the pendency of the ongoing investigations into their activities.

Estonia – criminal sanctions conviction for accepting funds from designated person

The Estonian authorities have secured a guilty plea as part of a plea deal by an individual who accepted funds from a designated person.

The accused, Tatjana Sokolova, received payments into Russian bank accounts from “The Foundation for the Support and Protection of the Rights of Compatriots Living Abroad” – a designated person under the EU’s sanctions.

The funds were withdrawn and carried into Estonia in person. The money was to be used to fund the defence of another individual who was being prosecuted for crimes against the Estonian state.

The sentence is for 360 hours of community service, with the 12-month unserved part of a 16-month prison sentence to be suspended pending completion of the community service.

Cash of €10,000 found when Sokolova was arrested has been confiscated and she was ordered to pay €1389 in court costs.

United Kingdom – sentencing for first Russian sanctions convictions

Further to last week’s post, sentencing has now been completed against Dmitrii Ovsiannikov and Alexei Owsjanikow, who were both convicted of breaches of the UK’s sanctions regime.

As per a press release from the Crown Prosecution Service, Ovsiannikov was convicted of 8 counts of breaking the asset freeze imposed upon him as a designated person, and has been sentenced to 40 months in prison for each count with each sentence to be served concurrently. He was also convicted of two charges of money laundering.

The charges relate to the purchase of a car, the payment of private school fees, deposits into bank accounts and insurance.

Alexei Owsjanikow was convicted of 2 of the charges against him, relating to the payment of school fees on behalf of his brother-in-law, and was given a suspended 15 month prison sentence and made subject of a curfew order.

United Kingdom – first criminal convictions under the UK’s Russian sanctions

It is being reported that the jury in the criminal prosecution of designated person Dmitrii Ovsiannikov, his wife Ekaterina Ovsiannikova, and his brother in law Alexei Owsjanikow have returned two guilty verdicts and one acquittal.

See our earlier posts on the progress of this case here and here.

These are the first criminal convictions obtained by the UK authorities under the UK’s Russian sanctions regime, and the first criminal conviction under any sanctions regime since 2017. It is also a rare example of the prosecution of a designated person.

Ekaterina Ovsiannikova was acquitted on four counts of circumventing sanctions arising from payments to her husband of £76,000 in 2023.

Alexei Owsjanikow was acquitted of several counts relating to access to a car, arranging car insurance and use of a bank account. He was, however, convicted of two counts of circumventing sanctions relating to the payment of £41,027 in private school fees.

Dmitrii Ovsiannikov was convicted of six of the seven counts he was charged with, all relating to breaches of the asset freeze imposed upon him by reason of his status as a designated person.

Sentencing will take place in due course, and it is to be hoped that the judge’s Sentencing Remarks are made public.

United Kingdom – export control compound penalties issued totalling £3.7m

Yesterday the UK’s HMRC issued a Notice to Exporters publishing three recent compound penalties issued to exporters.

In line with HMRC policy when agreeing to a compound penalty resolution, the information provided on the offending, the offender, and the co-operation provided is limited, although in this instance it is specified that the penalties do not relate to sanctions breaches. The detail available states:

The settlements relate to unlicensed exports of military-listed goods and related activity prohibited by The Export Control Order 2008 and contrary to The Customs and Excise Management Act 1979. These do not relate to sanctions offences.

The 3 settlements agreed with UK companies were:

  • January 2025 – £10,900.00 was paid for export license breaches in relation to the export of military goods controlled by The Export Control Order 2008
  • February 2025 – £431,232.20 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008
  • February 2025 – £3,231,762.40 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008“.

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The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

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