General – Page 5 – European Sanctions Enforcement

January 2, 2025January 2, 2025 by Mark Handley

Finland – sanctions investigation closed into returned Russian art

In April 2022 Finnish Customs seized over 200 pieces of art being shipped back to Russian museums such as the State Hermitage Museum and the Tretyakov Gallery.

It is now being reported that at that time an investigation was commenced by Finnish Customs working with the Finnish Foreign Ministry as to whether permitting the onward transit of the objects and artefacts, or the shipments themselves, would amount to breaching EU sanctions.

The artefacts were later allowed to travel on to Russia while the investigation continued.

As of 24 December 2024, it is now being reported (in the linked article above) that the investigation has concluded with no further action to be taken.

January 2, 2025January 2, 2025 by Mark Handley

Latvia – more than 100 criminal cases for sanctions breaches commenced during 2024

It has been reported that the Latvian authorities commenced 100 criminal cases for suspected sanctions violations during 2024.

In late October 2024 the figure was reported as 94, meaning that the final weeks of the year continued to see new criminal cases started.

The cases appear to be predominantly related to breaches of trade sanctions and the reporting states that the prohibited products included “engines, steel products and optical devices”.

December 20, 2024December 20, 2024 by Mark Handley

Estonia – person detained for alleged breach of designated person’s asset freeze

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.

December 20, 2024December 20, 2024 by Mark Handley

United Kingdom – three penalties imposed by HMRC for breaches of Russian trade sanctions

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.

FOI2024_232370 Download

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.

August 2022 – £1,000.00 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
- This penalty was previously described as relating to “unlicensed exports of dual-use goods”.
September 2022 – £19,689.20 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
- This penalty was previously described as relating to “unlicensed exports of dual-use goods”.
April 2023 – £217,012.50 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
- This penalty was previously described as relating to “unlicensed exports of dual use goods”.

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.

December 17, 2024April 3, 2025 by Mark Handley

United Kingdom – company convicted of export control violations

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 goods 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.

December 9, 2024December 10, 2024 by Mark Handley

Denmark – sanctions enforcement activity 2022-2024

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.

conclusion of a Danish FSA investigation into a payment services provider in January 2024: https://blogs.duanemorris.com/europeansanctionsenforcement/2024/01/19/denmark-danish-fsa-concludes-investigation-into-payment-services-provider/
a company and two individuals charged with sanctions offences relating to alleged arms exports to Russia in January 2024: https://blogs.duanemorris.com/europeansanctionsenforcement/2024/01/12/denmark-three-charged-in-relation-to-alleged-arms-exports-to-russia/
45 investigations opened between January and August 2023, of which 23 remained open and 2 had been referred to the Police: https://blogs.duanemorris.com/europeansanctionsenforcement/2023/08/16/denmark-45-sanctions-investigations-opened-so-far-in-2023/
two Russian designated persons referred to the Police by the Danish Business Authority in January 2023: https://blogs.duanemorris.com/europeansanctionsenforcement/2023/01/25/denmark-two-further-sanctions-investigations-referred-to-the-police/
12 criminal cases opened by the police and 34 investigations commenced by the Danish Business Authority between February 2022 and October 2022: https://blogs.duanemorris.com/europeansanctionsenforcement/2022/10/26/denmark-12-criminal-investigations-for-sanctions-breaches-opened/

December 9, 2024 by Mark Handley

Czechia – ongoing sanctions investigations into Czech companies

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.

December 5, 2024December 5, 2024 by Mark Handley

Germany – sanctions investigation into alleged exports to Belarus by politician’s company

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.

December 3, 2024 by Mark Handley

Latvia – prosecution for exports to Belarus in breach of sanctions

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.

November 27, 2024November 28, 2024 by Mark Handley

Poland – German national charged with exporting dual-use goods to Russia

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.

The press release is here.