Germany – sanctions enforcement statistics: at least 1988 investigations since February 2022

The German media outlet Südwestrundfunk has conducted a survey of Germany’s state justice ministries, public prosecutors office and the Federal Prosecutor’s Office to compile statistics on recent sanctions investigations in Germany.

The vast majority of these are said to relate to Russian and Belarusian sanctions although enforcement of other regimes is included.

The results are:

    • Saxony – 451 investigations
    • Bavaria – 448 investigations
    • Hesse – 406 investigations
    • Hamburg – 161 investigations
    • Schleswig-Holstein – 112 investigations
    • Brandenburg – 107 investigations (of which 38 discontinued)
    • Bremen – 103 investigations
    • Baden-Württemberg – 90 investigations (of which 52 in Stuttgart, of which 44 discontinued)
    • Rhineland-Palatinate – 73 investigations (of which 50 discontinued)
    • Saarland – 21 investigations
    • Mecklenburg Western Pomerania – 9 investigations
    • Thuringia – 7 investigations

This is a total of 1,988 investigations conducted since 24 February 2022. No data were reported for the states of Lower Saxony or Anhalt, so this figure is not complete.

In September last year (see earlier post) it was reported that there were 150 on-going investigations in Germany. The new survey reports a minimum of 176 investigations now reported as ongoing, although many regions did not provide a figure for currently ongoing investigations.

Poland – sanctions enforcement statistics including 20 fines to date

As part of the press article (behind a paywall) on the recent fines against Novatek Green Energy and Geleo (see our post here), the Polish authorities have also provided an update on their enforcement activity more broadly.

      • Total administrative proceedings commenced: 48
      • Final decisions to date: 33
      • Declination or waiver of fine or finding of no breach: 13
      • Fines imposed to date: 20
      • Ongoing proceedings: 15
      • Total fines to date: 4.8m zloty (c. $1.2m)

Certainly the figure for total fines does not include the fine against Novatek Green Energy (which was 12 million zloty), but it is also a little unclear whether or not the figure includes the fine against Geleo (which was 4m zloty).

The report also notes that most of the 20 penalties have been imposed in 2024, with only two imposed by the end of 2023 for a combined total of 71,000 zloty (c. $17,700).

These enforcement actions appear to relate to a mix of EU and the separate Polish sanctions.

No information has been provided as to the conduct which gave rise to the fines, or who the fines were imposed on.

Denmark – investigation closes into alleged import of fuel from partly Russian-owned refinery in India

Further to our earlier post regarding an investigation by the Danish Business Authority into allegations that the Danish shipping company Hafnia, was importing refined fuels from a refinery in India that may have been owned or controlled by Rosneft (which is a designated person under the EU’s sanctions), it is now being reported (here – behind a paywall), that the Danish Business Authority has concluded its investigation having determined that it could not establish that there had been a breach of Russian sanctions.

As yet the Danish Business Authority has not issued a statement on its website.

United Kingdom – HMRC corrects/changes description of earlier fine to withdraw reference to Russian sanctions

Back in April we posted about a Compound Penalty imposed by HMRC on a company for breaching the UK’s Russian Sanctions Regulations.

The company was fined £1,058,781.79.

HMRC has today issued a changed Notice to Exporters about this fine. The changed description removes any reference to the UK’s Russian sanctions regulations and replaces it with:

March 2024 – £1,058,781.79 was paid relating to the unlicensed exports of dual use goods controlled by Retained Regulation 428/2009“.

No explanation for the change is given.

Cyprus – enforcement update including first two sanctions cases referred for prosecution

It is being reported in Cyprus that two cases have been referred to the Prosecutor’s Office for instituting criminal proceedings. No other information was published on these matters.

In addition, yesterday the Economic Crime Investigation Unit provided updates to the Law Office on the progress with 10 of their ongoing cases, including (as we have previously noted) the investigation into asset transfers allegedly in breach of the EU’s sanctions by Alexei Mordashov.

 

The enforcement of sanctions circumvention in Europe

Sanctions circumvention. It is one of the key topics of the moment.

It is a routine question for people to ask which countries provide a circumvention risk. It is also a common perception that enforcement of sanctions circumvention is lacking.

Based on the material in this blog we have listed out below the more than 40 examples where of recent enforcement of sanctions circumvention on a third-country by third-country basis. Where a particular case involved circumvention via several countries they are listed separately.

Continue reading “The enforcement of sanctions circumvention in Europe”

Cyprus – sanctions investigation into purported share transfer by Mordashov in the “final stages”

Further to our earlier post there has been an ongoing investigation in Cyprus in relation to the alleged transfer of over $1 billion in shares by Alexey Mordashov in breach of the asset freeze imposed upon him by the European Union.

It is now being reported that the Cypriot investigation has reached its “final stages”.

The report gives no indication of the outcome of the investigation.

The allegations relate to transfers of the shares in the tourism operator Tui.

Finland – 700 Russian trade sanctions investigations of which 70 are large and complex

In September 2023, the Finnish Customs authorities announced they had 600 ongoing criminal investigations of which 60 were “aggravated”.

As reported in Wirtschaft Woche Sari Knaapi , the Chief Economic Crimes Investigator at Finnish Customs has now given details of the current figures, stating that there are now 700 ongoing investigations, with around 70 that are described as “large, complex cases”.

 

© 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.

Proudly powered by WordPress