Finland – CEO acquitted of sanctions charges

The result of a prosecution of a company’s CEO has been reported in the Finnish press.

The company received an order from a Russian customer for non-prohibited goods. The products then became sanctioned leading to a dispute as to whether the contract should be performed. The Russian customer threatened to bring a claim if there was no delivery.

The Finnish company’s CEO decided the best path was to go through some of the motions of an export, which would then be blocked, and this would be proof that delivery could not be made.

The company made an export declaration for the goods (motor switches), and it was at this point that the flaw in the plan became apparent.

Customs considered that the company was seeking to export sanctioned goods and investigated and charged the CEO with the appropriate sanctions breaches.

Luckily for the CEO the District Court of South Karelia this week has acquitted the CEO. The court relied on the fact that the company had taken no steps to move the goods from its warehouse, and the court found that there was no real intention to actually export.

I am very grateful to Aleksi Pursiainen, of Solid Plan Consulting, for drawing this case to my attention.

If ever there was a cautionary tale on the drastic consequences that can come from not having appropriate sanctions wording in your contracts, this is it.

Jersey – investigation into suspected Russian sanctions offences

Reporting by the Guardian newspaper has flagged an ongoing sanctions investigation in Jersey that this blog had previously missed.

The investigation has become public as a result of a Swiss judgment relating to a mutual legal assistance request for documents made to Switzerland by the Jersey authorities. The court dismissed a challenge to the provision of the documents.

As well as investigating allegations of corruption going back to the 1990s the Jersey authorities are said in the judgment to be investigating:

i) the continued use of the funds and assets of two Jersey companies (named only as J Ltd and K Ltd) after the the person who is alleged to indirectly control the companies was placed on Jersey’s Russian sanctions list;

ii) that companies continued to provide the designated person with financial services after his designation; and

iii) an attempt that was made to transfer the assets of J Ltd after the person’s designation.

The judgment itself does not name the designated person, but press reporting has identified the person as Roman Abramovich.

The Guardian also notes that lawyers for Mr Abramovich denied the allegations.

Spain – appeal court upholds pre-trial detention in Russian sanctions prosecution case

Press reporting has brought to light a Spanish judgment upholding the pre-trial detention of a Georgian national named only “Alexander” who is suspected of exporting a range of goods and machinery to Russia via Turkey.

The judgment is here.

It is alleged that the individual had company seals for a range of Spanish, Turkish and Russian companies and was able to prepare documentation that gave the appearance of legitimate exports to Turkey.

WhatsApp messages, however, are said to have revealed the end-customers in Russia.

It is unclear whether this judgment relates to another Spanish investigation related to the export of machinery through third countries (see our earlier post), or is a separate investigation.

United Kingdom – enforcement statistics (badly described)

As part of the just-published UK’s Economic Crime Plan 2: outcomes progress report, the UK government has included the following data on the enforcement of financial sanctions:

396 recorded cases of financial sanctions breaches in the financial year ending 2024, a 16% decrease on the previous year, but there were 242 closed cases – more than tripling the number of closed cases from the previous year“.

If the UK had identified 396 actual breaches of sanctions, this would beg the question of why there has been so little enforcement. There is, however, reason to question the data in this announcement.

In OFSI’s latest annual report (see our earlier post) OFSI stated:

OFSI progressed a substantial number of investigations during 2023-24, recording 396 cases and closing 242, more than tripling the number of closed cases from the previous year“.

OFSI’s report is the source of the figures of 396 and 242. It would seem, therefore, that the figure of 396 relates not to identified breaches of sanctions, but to the number of financial sanctions investigations OFSI conducted during 2023-24.

Estonia – extradition to US on charges of supplying US goods to Russia

The US Department of Justice has issued a press release confirming that the Estonian authorities have transferred Estonian national Andrey Shevlyakov to US custody for extradition to the US to face 18 counts of supplying US goods and technology to Russia in breach of US sanctions.

It is being reported that Mr Shevlyakov was first detained in March 2023 as part of a joint investigation between US and Estonian authorities.

European Sanctions Enforcement – round up of a busy summer

It has been a busy summer on the enforcement front but the blur of repeated individual announcements can, ironically, mask the scale, breadth and scope of the current level of enforcement activity taking place across Europe.

So to help we have put all the posts since June into one place.

Collectively these paint a picture of enforcement in 19 different countries (20 if you want to count Guernsey separately). Of these 16 are EU member states with enforcement also seen in the UK, Switzerland and Iceland.

There have been 7 criminal convictions generating 19.5 years of jail time, and fines and confiscations of over €9m , as well as multiple raids of companies and homes (in Bulgaria, Denmark, Estonia, Germany, Italy, Latvia, Lithuania, the Netherlands, Portugal and Spain), not to mention the announcement of multiple arrests and investigations. And this is just what is public.

For those who remember what enforcement used to look like before 2022, activity like this is fairly extraordinary.

Bulgaria

Czechia

Denmark

Estonia

Finland

France

Germany

Greece

Guernsey

Iceland

Italy

Latvia

Lithuania

Malta

Netherlands

Portugal

Spain

Sweden

Switzerland

United Kingdom

Latvia – investigations into sanctioned Belarusian urea imports

It is being reported that the Latvian authorities have been conducting multiple investigations into suspected imports of urea from Belarus in breach of the EU’s sanctions.

The investigations are reported to be focussed on four Latvian companies and were commenced in July.

After a referral from the Customs Administration the VID Tax and Customs Police Department initially declined to prosecute, but that decision is now the subject of an appeal brought by the Customs Administration and Latvia’s FIU.

Estonia – prosecution of lawyer for sanctions offences

Further to our earlier post, the Estonian authorities have decided to prosecute an Estonian lawyer for alleged breaches of sanctions. The Prosecutor’s Press Release states that attorney Urmas Simon has been charged with making an economic resource available to the designated person Pravfond, in the form of legal services to a third party paid for by Pravfond. Mr Simon is also charged in relation to taking payment from the sanctioned entity.

UK – suspended custodial sentence for refusal by designated person to provide financial information

Further to our earlier post, sentence has been passed in relation to the conviction of Aozma Sultana for refusing the provide financial information to OFSI despite repeated requests. The judge noted that the information had still not been provided.

The judge stated that the starting point for such an offence should be a custodial sentence of 15 weeks. Evidence was presented, however, that Aozma Sultana was the primary care provider for her 38-year-old wheelchair-bound brother, who suffers from cerebral palsy.

On that basis the judge sentenced to Aozma Sultana to 10 weeks’ imprisonment, suspended for 12 months. The court also ordered Sultana to complete 50 hours of unpaid work and 25 days of rehabilitation. 

Switzerland – 13 administrative penalties for sanctions offences (March 2024 to July 2025)

Further to our earlier posts publishing the Administrative Penalties imposed by Switzerland’s SECO, we are providing details of a further 13 penalties imposed.

The blog is grateful to SECO for providing anonymised copies of the penalty notices.

16. Final administrative decision, dated 18 March 2024 (I.36)

Notice.

SECO was notified by Customs at Geneva Airport following the seizure of weapon parts imported from Russia.

SECO pend an investigation and determined that the parts were not for weapons intended for hunting or sport.

The importer was individual who had ordered the goods from a Russian manufacturer. This is the first instance of a fine imposed on individual by SECO for Russian sanctions breaches.

SECO assessed the breach as negligent rather than intentional, and imposed a fine of CHF 300, plus costs of CHF 360. The imported items were confiscated.

17. Administrative penalty dated 18 March 2024 (I.72)

Notice.

This notice relates to the attempted export of 4 leather bags each valued at €370, with a total value of €1,480.

The goods were returned to seller.

The notice states that this was a repeat infraction by the company in question, with it having been the subject of proceedings that were dismissed on 19 December 2022.

The export was said to be result of human error during a busy time and SECO took the view that the breach was negligent and not intentional.

The company was fined CHF 1000 with costs of CHF 560.

18. Administrative penalty dated 23 May 2024 (I.75)

Notice.

SECO’s proceedings were commenced on 8 January 2024 and relates to an attempted export by a Russian national to Russia of luxury jewelry valued at CHF 14,100 and seized at Zurich airport.

The jewelry had been sold to that person with a VAT exemption on the basis that the person was a tourist. The invoice issued by the selling company referred to the individual as resident in the Russian Federation.

SECO accepted that the breach by the seller was negligent and not intentional, and imposed a fine of CHF 4,500, and costs of CHF 1260.

The Notice contains no indication of confiscation of the proceeds from the sale, but will be of interest for sellers of luxury goods to Russian nationals, especially where there is a reason to think that the goods would be taken to Russia.

19. Administrative penalty dated 23 May 2024 (I.91)

Notice.

The investigation was started on 27 February 2024, following the shipment of 12 electric heating resistors valued at CHF 6,400 bound for Russia and stopped at Zurich airport.

SECO determined that the breach was not intentional, but a result of a negligent failure to understand which products codes were prohibited. The company was noted as having cooperated.

A fine of CHF 1,000 was imposed plus CHF 1,260 in costs.

20. Administrative penalty dated 5 June 2024 (I.80)

Notice.

This is a short notice with substantial redactions. It relates to the attempted export of flowmeters and electric motors to Russia of uncertain value.

The company was fined CHF 700 plus costs of CHF 40.

21. Administrative penalty dated 17 June 2024 (I.84)

Notice.

This Notice relates to the attempted export of prohibited goods to Russia, being spare parts for machine tools.

The goods were not confiscated but were released back to the exporter.

The company was fined CHF 500, plus costs of CHF 650.

22. Administrative penalty dated 9 September 2024 (I.90)

Notice.

This Notice relates to prohibited imports of plastic packaging from Russia valued at c. €3,536. The goods had been donated to assist with medical research and had not been purchased.

SECO took the view the breach was negligent and not intentional and imposed a fine of CHF 500 plus costs of CHF 580.

23. Administrative penalty dated 9 October 2024 (I.94)

Notice.

This relates to an attempted export referred by Swiss Customs to SECO. Seven different categories of goods were involved, six of which were prohibited from export. The goods were valued at more than CHF 15,000.

The lawful export was allowed to proceed and the others goods were all returned to the exporter rather than being confiscated.

The company had conducted google searches to determine whether the goods were subject to prohibitions, but these provided faulty answers. SECO determined the breach was negligent and not intentional and so fined the company CHF 5,000, plus costs of CHF 1,460.

24. Administrative penalty dated 18 December 2024 (I.101)

Notice.

This Notice relates to an attempted export of satellite parts to Ukraine without a licence. SECO approved a retrospective licence application to allow the export to proceed but imposed a fine of CHF 1000 plus CHF 20 in costs.

Previously SECO had taken the view that it was not permissible to apply for retrospective licences.

25. Administrative penalty dated 5 November 2024 (I.93)

Notice.

The Notice relates to the importation of prohibited goods valued at €22,650 reported to SECO by Swiss Customs. SECO commenced its investigation in July 2024. The goods in question were an electrical cabinet with customs code 8537.1000.

The importer had obtained erroneous advice that the goods had a non-prohibited customs code.

SECO prosecuted for negligent breach and imposed a fined CHF 5,000 plus CHF 850 in costs.

26. Administrative penalty dated 9 May 2025 (I.109)

Notice.

This Notice relates to an import shipment from Russia seized at Basel Airport and referred to SECO consisting of clothing valued at CHF 28,689. These were imports prohibited under Switzerland’s Russian sanctions.

SECO accepted evidence from senior company representatives that they were unaware of the existence of the prohibitions, and so SECO proceeded on the basis of a negligence, rather than an intentional, breach.

A fine of CHF 2000 plus CHF 300 in costs was imposed.

27. Administrative penalty dated 11 June 2025 (I.110)

Notice.

This Notice relates to the attempted export to Russia of goods of uncertain value with classification codes 8544.4200 (insulated cables), 3917.4000 (plastic fittings) and 8481.8000 (valves and other fittings). The exporter is said to have applied for, and been granted, a licence after the event.

The company was fined CHF 800 plus CHF 20 in costs.

28. Administrative penalty dated 9 July 2025 (I. 114)

Notice.

This Notice relates to the seizure of goods valued at CHF 11,739 bound for export to Russia, with no licence having been sought, and with product code 9027.5000 (instruments for physical or chemical analysis).

The company was fined CHF 1000 with CHF 20 in costs. The fine is described as having been for the failure to obtain a licence, and not for the attempted unlicensed export itself.

The Notice does not indicate whether the goods were returned to the exporter or confiscated.

© 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