It is being reported that the Higher Regional Court in Stuttgart has convicted Ulli S, a 56 year old man, of breaches of the EU sanctions against Russia and the German foreign trade law.
The exports were of machinery which can be used for the manufacture of sniper rifles and other weapons. Some of the exports were sent to Russia via Switzerland and others via Lithuania, while the customs data was falsified.
The contracts for the supply of the goods had been entered into in 2015.
The individual is said to have profited by 2.1 million euros, while a Swiss holding company benefitted by roughly 3 million euros. According to Der Spiegel these sums have been confiscated.
The trial lasted several months and is subject to a possible appeal.
The Solicitors Regulation Authority for England and Wales has, in its Annual Report for Money Laundering covering 2023/2024, has stated that it has required 9 law firms to report themselves to the Office of Financial Sanctions Implementation.
In eight of these instances the breach was a breach of a licence condition. It is unclear whether these were specific licences or a General Licence. The breaches are said to have varied between late or no reporting, and taking payments not actually covered by the licence in question.
While many have related to the UK’s Russian sanctions no information is given as to the identity of the sanctions regime(s) in question.
In a reported interview with Raimonds Zukuls, the Deputy Director General of Latvia’s State Revenue Service, details of ongoing enforcement activity in Latvia have been provided.
These figures are specific to the EU’s sanctions against Russia and Belarus and include:
94 criminal proceedings commenced during 2024;
more than 300 criminal proceedings overall (nb. as per our earlier post,the figure was 310 back in February 2024);
2170 instances of blocked exports/imports during 2023; and
more than 2400 instances of blocked imports/exports during 2024.
Zukuls is also quoted as saying that the most frequent blocked exports to Russia and Belarus were cars, tractors, electrical equipment and appliances, and the most frequent blocked imports from Russia and Belarus were wooden products, animal feed and metal products.
Belgium, Bulgaria, Croatia, Cyprus, Denmark, France, Greece, Hungary, Ireland, Luxembourg, Malta, Moldova, Portugal, Slovakia, Slovenia, Spain, Sweden – 0
Czechia, Italy, Norway, Romania – 1
Finland – 4
United Kingdom and Lithuania – 7
* The Estonia figure is uncertain based on this story, but how high/low is uncertain.
Most currently-ongoing investigations:*
Finland – 800
Latvia – 310
United Kingdom – 307
Netherlands – 192
* Germany probably belongs on this list. It has commenced at least 1988 investigations since February 2022, but many of the States that responded to Freedom of Information Requests did not provide data on ongoing investigations, but only the total number of investigations commenced since the start of the full-scale war.
Longest custodial sentencessince 2017 (where the sanctions element can be distinguished):*
* The list excludes convictions where there are also non-sanctions offences and where the sentence cannot be divided, such as the 19-year sentence imposed in the Netherlands which included war crimes offences.
Most extraditions to the United Statesto face US sanctions charges
Latvia – 4
Cyprus, Estonia, Spain, United Kingdom – 2
Croatia, Germany, Greece, Italy, Romania – 1
All other European countries are at zero.
Highest total value of fines/confiscations/penalties (in Euros) since 2017:
United Kingdom – €268,344,548 (of which the FCA’s fines make up €228,465,751)
France – €50,600,000
Germany – €26,112,903
Lithuania – €23,513,079
Lowest total value of fines/confiscations/penalties(in Euros) since 2017 where value is known:*
Bulgaria, Croatia, Cyprus, Greece, Hungary, Ireland, Moldova, Portugal, Slovakia, Slovenia, Spain and Sweden – €0
It is being reported that the Swedish authorities have commenced three preliminary investigations into possible Russian sanctions breaches during 2024.
No other information has been made public, but the investigations appear to relate to trade sanctions.
It is being reported that Norway’s Politiets Sikkerhetstjeneste (Norwegian Customs), has 37 ongoing investigations in relation to alleged breaches of Norway’s Russian sanctions. Many of these are said to involve attempts to evade detection by exporting to Russia via third countries, but some are described as relating to imports into Norway.
It is also being reported that there is a further investigation under Norway’s Export Control Act.
Further to our earlier post from February 2024, it is being reported that the Paris Court has ordered that the prosecution of the French cement maker Lafarge and eight individuals on charges of terrorist financing and breach of EU sanctions against ISIS should proceed to trial.
The case is part of a long running saga arising from allegations that the company paid money to ISIS in order to keep a cement plant open and operating.
OLAF – the European anti-fraud agency – has issued a press release setting out the assistance it has given to Spain’s National Police. The assistance appears to have been largely on the intelligence and analysis side.
As stated in the press release:
“As part of the investigation, the Spanish National Police and Customs Surveillance Service arrested four individuals in the Spanish region of Catalonia, three of whom are Russian nationals. The operation also resulted in the seizure of 13,000 kilograms of a chemical compound subject to export restrictions, at the Port of Barcelona.
The investigation revealed that a Spanish company, managed by Russian nationals, had established a sophisticated logistical and economic scheme to export internationally sanctioned chemical products to Russia. This network involved the use of shell companies in Armenia and Kyrgyzstan to disguise the true destination of the goods, which were later rerouted to Russia”.
The Police have also issued a press release, stating that the arrests were in the Catalan towns of Sant Feliu de Guisols (Girona), Cerdanyola del Vallès and Santa Perpètua de Mogoda (Barcelona), and that the operation included searches at residential properties.
This is the first announced enforcement of EU sanctions in Spain since April 2023.
This is also the first announced operation said to have been aided by intelligence-gathering by OLAF.
The investigation of all three individuals continues, with two having been released from custody over the summer and the third recently released.
The conditions of bail include a travel ban, and it is said that the three are being investigated in relation to the “gross regulatory crime” of exporting dual use goods from Finland to Russia in breach of EU sanctions.
It is unclear whether this case is related to Tampere University recently reporting itself to the Finnish police.
With the news of OFSI imposing a civil penalty, Europe has today hit its 300th successfully-concluded enforcement action in relation to trade and financial sanctions and export controls since the start of 2017.
To mark the occasion we are publishing updated enforcement graphs which we last posted back in January when this blog first went live.
Total number of fines/penalties/convictions: 2017-2024
As the graph shows 2024 has, to date, been the most prolific in terms of sanctions enforcement in recent years with 69 so far this year. Already there have been three times as many successfully-concluded enforcement actions in Europe in 2024 as there were in 2017.
Total value of fines/penalties: 2017-2024
While the volume of enforcement has increased, the shape of this graph illustrates that the value of the fines imposed did not keep pace in the years following when the UK and French financial services regulators having imposed fines of £102m, €50m, and £38m.
After several years of plateau 2024 is, however, showing signs of acceleration with fines of over €32m imposed so far this year – more than double the figure for 2023.
Russian / Belarusian sanctions enforcement
Focusing just on enforcement of the sanctions against Russia and Belarus, perhaps unsurprisingly, the picture varies across Europe, although the total of 111 examples to date is worth stressing in and of itself.
This graph includes only enforcement actions that have concluded with a fine, penalty, conviction or confiscation. A total of 18 countries show no examples, although it is possible that there are such examples and they have not been made public. Poland, the Netherlands, Switzerland and Latvia are the only countries with more than 10 examples.
This is another way of looking at the same data. Again, this is specific to the Russia/Belarus sanctions, and is the number of concluded enforcements. This does not reflect the scale of the fines. A few countries dominate the picture.
Current investigations
Looking at publicly-available data on the number of current/live investigations reveals a similar picture. Many states appear to be currently inactive, while there are more than 2000 investigations which are reported as ongoing across Europe. That is a figure which bears repeating – more than 2000 ongoing regulatory/criminal sanctions investigations across Europe.
It should be remembered, however, that for most states such information has not been made public. In Germany alone nearly 2000 investigations have been started since early 2022, but the information is limited on how many of these remain active.
