Germany – report that there are 6,000 criminal proceedings for Russian and Belarus sanctions breaches ongoing

It is being reported in an article published in trans.info that the German authorities currently have approximately 6000 criminal proceedings for sanctions offences that are ongoing.

This number is said to be specific to the EU’s Russian and Belarusian sanctions regimes.

No further information is provided on the status of the cases.

Latvia – prosecution for providing professional services to Russian companies

Latvia’s VDD has asked the Prosecution Office to commence a prosecution of a latvian national for providing prohibited services to companies in Russia.

As per the press release: “DD found that the Latvian citizen had entered into employment contracts with multiple companies registered in Russia, where the person held the positions of general director and director and directly gave prohibited consultations on economic activities, management and taxation”.

This prosecution is one of several recently launched in Latvia (see our earlier post) in relation to alleged breaches of the prohibitions contained in regulation 5n of 833/2014.

United Kingdom – Gambling Commission fine of £825,000 including for sanctions screening failures

The UK’s Gambling Commission has fined Done Brothers (Cash Betting) Limited, trading as Betfred £825,000.

While much of the fine relates to player welfare and AML issues, it is being reported that part of the fine relates to the lack of an “effective policy for identifying and handling customers who might be subject to financial sanctions”.

This is not the first fine by the Gambling Commission related to sanctions compliance, as two other operators were fined in April 2024.

Netherlands – further arrests and raids related to Damen Shipping

it is now being reported that the raids conducted by FIOD earlier this week (see our earlier post) relate to a new and further investigation into alleged Russian sanctions breaches by Damen Shipping, and that the raids included searches conducted at the home of the former Damen CEO.

This new investigation is said to be unrelated to the ongoing trial in which Damen is being prosecuted for alleged Russian sanctions breaches.

Finland – two individuals charged with sanctioned export offences

Further to our earlier post, it is now being reported that the Finnish authorities have charged the two remaining defendants (the first having plead guilty) on suspicion of exports to Russia of dual-use drones, laptops, computer processors, smartphones and laser rangefinders in breach of the EU’s sanctions.

The value of the exports is said to have been around €140,000, with the exports said to have taken place between 2022 and 2024.

Germany – raids and arrests as part of investigation into exports of equipment to Russia

German Customs has issued a press release relating to an ongoing investigation against five defendants. On 29 November three properties were raids in Oelde, and two individuals were arrested.

The investigation by the Essen Customs office, relates to the export since January 2023 of technical equipment and accessories, such as pumps, valves, filters to a company in Russia.

It is suspected that 53 shipments may have taken place via third countries.

The investigation has also frozen assets valued at €689,000.

Estonia – four criminal convictions for Russian sanctions offences

The website containing published judgments from the Estonian courts has published a number of judgments relating to convictions for sanctions offences.

1. Conviction of Adilov Mubariz on 23 July 2025

      Decision: https://www.riigiteataja.ee/kohtulahendid/detailid.html?id=413740161

      This individual was convicted of importing a few hundred Russian cigarettes into Estonia in breach of Article 3(i)(1) of EU Regulation 833/2014. This was a second offence.

      The man was given a 3-month jail term, suspended for a 12-month probation period, and ordered to pay €798.42.

      2. Conviction of Alus Grupp OÜ and Taras Potapov on 18 September 2025

      Decision: https://www.riigiteataja.ee/kohtulahendid/detailid.html?id=419399125

      Mr Popatov was convicted of aiding and abetting the provision of a service related to a prohibited strategic good, namely resonance testing machines used in the aviation and aerospace industries. These are dual use goods

      The company Alus Grupp is a freight forwarder and Mr Popatov was one of its directors.

      Another Estonian company and its director purchased the equipment from a supplier in Switzerland and sold them to Russian customers. The invoices showed that the intended ultimate customer was a Russian company. Alus Grupp and its director, being aware of the ultimate customer, on multiple occasions transported the goods to Kazakhstan. On other occasions an intermediary based in the UAE was inserted.

      Mr Popatov was convicted. At the time of his conviction he had already served 5 months in jail. Pursuant to an agreement with the prosecution, the remainder of his 5-year sentence was suspended subject to a 5-year probation period. He was also ordered to pay a penalty of €2,215.

      The company was also convicted and given a fine of €100,000 with a further €200,000 suspended for a 5-year probation period.

      The judgment gives a detailed account of the exporting arrangements. It appears that other prosecutions of the actual exporting parties are ongoing.

      3. Conviction of Anna Shmeljova on 14 October 2025

      Decision: https://www.riigiteataja.ee/kohtulahendid/detailid.html?id=422536761

      Ms Shmeljova was convicted of multiple offences including exporting luxury goods to Russia, namely clothing and hockey skates, and importing cigarettes.

      She was ordered to pay €2,215, and given a five-month jail sentence suspended for a one year probation period.

      4. Conviction of Marine Technics Baltia OÜ and Daniil Haitin on 5 November 2025

      Decision: https://www.riigiteataja.ee/kohtulahendid/detailid.html?id=424933869

      Mr Haitin was convicted of four offences and sentenced to 4 years and eleven months in jail. This sentence was suspended for a 5 year probation period. He was ordered to pay €2,215.

      The company Marine Technics was convicted of two offences and ordered to pay €160,000, as well as €13,251.65.

      The offences related to exports of gas generators, alternators, propulsion systems, thermal cameras and other equipment to Russia, including to military end-users such as Kalashnikov Concern, and the Russian Ministry of Defence.

      False end-user certificates were prepared showing purported customers in Turkey.

      The offending had taken place between 2017 and 2019.

      The judgment notes that the court had prevented the merger or winding up of Marine Technics Baltia OÜ for the duration of the investigation in order to be able to secure a conviction and penalty.

      The judgment gives a detailed account of the exporting arrangements.

      Ireland – multiple cash seizures related to sanctions circumvention network

      It is being reported that the Gardaí have conducted multiple cash seizures targetting a criminal network used for laundering money and sanctions circumvention.

      The seizures value €1.36m and took place in multiple operations in Dublin and Leitrim in April and October this year.

      It is alleged that the network “cleaned” the proceeds from ilegal activity and turned it into crypto currency. It is also alleged that the network provided sanctions circumvention services to the Russian state.

      The Irish seizures were part of the broader Operation Destabilise which involved the UK’s National Crime Agency (see our post).

      © 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