Category: General

Posted on by Mark Handley

United Kingdom – CPS advising on two further criminal prosecutions

Global Investigations Review (behind a paywall) has published the results of a Freedom of Information request to the Crown Prosecution Service which reveals that the CPS has been asked to advise on a total of three cases under Russian sanctions, two of which are not otherwise in the public domain.

One of the newly-revealed relates to financial sanctions, and the other to trade sanctions.

The third case relates to the ongoing prosecution of three individuals.

The CPS has not yet added this Freedom of Information response to its website.

Posted on by Mark Handley

European sanctions enforcement: the custodial sentences

Although one of the filters on this blog is “custodial sentence”, I thought it might be helpful to collect all the examples in one place.

As such, here is the full list of custodial sentences that have been imposed across Europe for sanctions offences since 2017. Please note this excludes suspended sentences.

2017:

2018:

2019:

2020:

2021:

2022:

2023:

2024:

Overall the figures are dominated by the Netherlands and Germany with approximately 68 of the 80 years of sentences between them. Indeed, as the graph below demonstrates, other than Finland’s 40-day sentence for breaching a travel ban, the Netherlands and Germany are the only European countries to have sent someone to prison for sanctions offences since 2019.

Posted on by Mark Handley

Germany – seven year sentence for exports of military and dual-use goods to Russia and confiscation of profits

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.

As per our earlier posts, the man was arrested in August 2023, and had been charged in November 2023.

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.

Posted on by Mark Handley

United Kingdom – 9 law firms referred for investigation for possible sanctions breaches

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 may have related to the UK’s Russian sanctions no information is given as to the identity of the sanctions regime(s) in question.

Posted on by Mark Handley

Latvia – 94 criminal proceedings commenced this year for Russia/Belarus sanctions breaches

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.

Posted on by Mark Handley

European Sanctions Enforcement – performance league tables (2017-2024)

The figures are, naturally, based on publicly-available information as collated in this blog.

The figures are not always easy to reconcile into a coherent picture. For example:

  • The Netherlands has the most convictions, but none of the longest sentences;
  • Germany has far fewer convictions than the Netherlands, but all of the longest sentences;
  • Finland has a massive number of ongoing investigations but has only imposed fines to date of €11,080;
  • Switzerland has 15 convictions, but no custodial sentences and €58,435 in fines;
  • Poland has the highest number of successfully-concluded enforcement actions under the Russian sanctions but has no criminal convictions; and
  • The UK dominates the figures on total fines, but has a low number of criminal convictions.

Most criminal convictions since 2017:

  1. Netherlands – 40
  2. Switzerland – 15
  3. Germany – 10
  4. Latvia – 7

Fewest criminal convictions since 2017:

  1. Austria, Bulgaria, Croatia, Cyprus, Estonia, France, Greece, Hungary, Ireland, Lithuania, Luxembourg, Malta, Moldova, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden – 0
  2. Czechia and Norway – 1
  3. Denmark, Italy and United Kingdom – 3

Most Russian/Belarusian sanctions convictions/fines/penalties since 2017:

  1. Poland – 24
  2. Netherlands – 21
  3. Switzerland – 15
  4. Latvia – 11

Fewest Russian/Belarusian sanctions convictions/fines/penalties since 2017:*

  1. Belgium, Bulgaria, Croatia, Cyprus, Denmark, France, Greece, Hungary, Ireland, Luxembourg, Malta, Moldova, Portugal, Slovakia, Slovenia, Spain, Sweden – 0
  2. Czechia, Italy, Norway, Romania – 1
  3. Finland – 4
  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:*

  1. Finland – 800
  2. Latvia – 310
  3. United Kingdom – 307
  4. 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 sentences since 2017 (where the sanctions element can be distinguished):*

  1. Germany – 7 years (2020)
  2. Germany – 6 years and 9 months (2024)
  3. Germany – 5 years (2023)
  4. Germany – 3 years and 9 months (2021)

* 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 States to face US sanctions charges

  1. Latvia – 4
  2. Cyprus, Estonia, Spain, United Kingdom – 2
  3. Croatia, Germany, Greece, Italy, Romania – 1
  4. All other European countries are at zero.

Highest total value of fines/confiscations/penalties (in Euros) since 2017:

  1. United Kingdom – €268,344,548 (of which the FCA’s fines make up €228,465,751)
  2. France – €50,600,000
  3. Germany – €26,112,903
  4. Lithuania – €23,513,079

Lowest total value of fines/confiscations/penalties (in Euros) since 2017 where value is known:*

  1. Bulgaria, Croatia, Cyprus, Greece, Hungary, Ireland, Moldova, Portugal, Slovakia, Slovenia, Spain and Sweden – €0
  2. Norway – €4260**
  3. Finland – €11,080
  4. Switzerland – €58,435
  5. Czechia – €143,500

* Malta has imposed a fine of unknown size but greater than €800, and Austria has imposed at least 10 fines of unknown value.

** This is an underestimate for Norway as it has concluded 23 confiscations of goods where no value was published.

Highest single fines/confiscations/penalties within 2024

  1. UK – £29m by the FCA
  2. Lithuania – €13.6m by Customs
  3. Lithuania – €8.23m by the Financial Crimes Investigation Service
  4. Poland – €2.78m by Customs

Most successfully-concluded enforcements within 2024

  1. Poland – 22
  2. Netherlands – 10
  3. Lithuania – 7
  4. Switzerland – 6
  5. UK – 5*
  6. Germany – 4
  7. Luxembourg – 3
  8. Estonia – 2**
  9. Finland – 2
  10. Latvia – 2
  11. Czechia – 1
  12. Malta – 1
  13. All other European countries are at zero.

* The UK figure excludes export control enforcements unrelated to sanctions.

** The Estonia figure is likely to be higher based on this story, but how much higher is uncertain.

Posted on by Mark Handley

Norway – 37 ongoing Russian sanctions investigations

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.

Posted on by Mark Handley

France – prosecution of Lafarge for ISIS sanctions breaches to go to trial

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.

Posted on by Mark Handley

Spain – four arrested and sanctioned cargo seized in OLAF-assisted investigation

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.

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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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