Infrastructure and Transport (including energy) – European Sanctions Enforcement

January 17, 2025January 17, 2025 by Mark Handley

Germany and Finland: sanctions investigations re seized “shadow fleet” vessels

It is being reported that the Panama-flagged vessel, the Eventin which has been seized and detained by Germany after it lost power on 10 January, is currently the subject of a sanctions investigation by the General Customs Inspection Office.

The investigation relates to the cargo of 100,000 tons of oil on board.

In a similar story, it is being reported that the Finnish authorities have concluded an investigation into possible sanctions breaches in relation to the Eagle S, the vessel suspected of being involved in disruption to undersea cables.

The Finnish authorities investigated the cargo of unleaded petrol and diesel on board, but determined that as the vessel only entered Finland’s territorial waters at the request of the Finnish authorities it cannot be said to have intentionally violated the prohibitions on the import of Russian oil products.

December 20, 2024December 20, 2024 by Mark Handley

Finland – aircraft detained for suspected involvement in sanctions evasion

It is being reported that a Lithuanian-registered aircraft being flown from Latvia to Russia via Finland has been intercepted and detained at Helsinki airport due to suspicions of sanctions evasion.

The pilot of the aircraft has been reported to have been involved in a number of previous alleged aircraft sales to Russian customers.

December 17, 2024December 17, 2024 by Mark Handley

Estonia – police and border guards conduct over 240 inspections of Russian “shadow fleet” vessels

It has been reported that Estonia’s police and border guards have between them conducted over 240 inspections of vessels in waters of Estonia’s economic zone in the last 6 months. Estonia adopted the policy of conducting inspections in June of this year.

The vessels are said to belong to Russia’s so-called “shadow fleet” and the inspections relate to verifying compliance with requirements such as valid insurance.

December 10, 2024December 10, 2024 by Mark Handley

Netherlands – third defendant found guilty in sanctioned aircraft parts export prosecution

Further to our earlier posts from 8 October and 7 October relating to the conviction of a company and individual for exporting aircraft parts to Russia in breach of EU sanctions, the Rotterdam District Court ruled on 22 November that the third co-defendant is also guilty.

The judgment is here.

The individual was an employee of the Ministry of Defence and was first arrested in September 2023 (see our earlier post).

The conviction was based on the export of parts via Tajikistan, Kyrgyzstan, Turkey the UAE and Serbia. The Defendant was also convicted of falsifying documents and of a minor fire arms charge.

The court accepted findings of PTSD by court psychologists and the probation service.

At sentencing the court stated: “In view of the seriousness of the proven facts, from the point of view of general prevention, a prison sentence of considerable duration is in principle appropriate“.

In the circumstances of the defendant, however, the custodial sentence was limited to the period of pre-trial detention with a further period of 195 days suspended for two years. In addition 240 hours of community service was imposed.

The individual was also disqualified from acting as a company director for three years.

December 9, 2024December 9, 2024 by Mark Handley

Hungary – fine imposed on individual for imports from Russia

It is being reported that Hungarian authorities have reached a settlement to resolve the prosecution of an individual identified as M.M.

The prosecution was based on importing car parts from Russia, via Belarus, in breach of the EU’s sanctions.

The imports are said to have been valued at HUF 35 million (€84,500), and the agreed settlement was for a fine HUF 1 million (€2,400), the confiscation of the imported parts and the payment of legal costs.

This is the first known example of an enforcement action in Hungary.

November 25, 2024November 25, 2024 by Mark Handley

Germany – three individuals in custody for exporting nearly 100 cars to Russia in breach of sanctions

It is being reported that the Mannheim Public Prosecutor’s Office has three people in custody on suspicion of exporting luxury cars to Russia in breach of EU sanctions.

A car manufacturer made a suspicious activity report regarding the exporter, which led to the investigation.

The three individuals are a married couple who run two car dealerships and a third person who was an employee.

It is alleged that they exported nearly 100 cars to Russia via third countries with a total value of nearly €15 million.

As part of the raids, the prosecutors also secured the freezing of €1.3 million.

November 8, 2024November 8, 2024 by Mark Handley

United Kingdom – revised (and increased) figures for the number of OFSI’s oil price cap investigations: 60 to date

As of 27 September 2024, the position as regards OFSI’s investigations into alleged breaches of the UK’s oil price cap was as follows (covering the period from 5 December 2022 to 21 August 2024:

total number of investigations commenced: 60
total number of investigations commenced where the alleged suspect is a UK person or company: 52
total number of investigations which remain open: 42
total number of investigations which remain open where the alleged suspect is a UK person or company: 37

These figures revise those we published last month which were based on the BBC’s reporting of the results of a Freedom of Information request it had made to OFSI.

After obtaining a copy of what was released to the BBC by making our own Freedom of Information request we have been able to revise the figures. The BBC did not include in its figures the investigations into non-UK persons potentially breaching the UK’s oil price cap.

What the complete figures reveal is that a further 8 investigations have been commenced into non-UK persons suspected of breaching the oil price cap, of which 5 remain ongoing.

A copy of HM Treasury’s response to our asking for the response provided to the BBC is here.

FOI2024-15950 – Copy of FOI release redacted Download

October 31, 2024October 31, 2024 by Mark Handley

Germany – raids related to luxury car exports of €10m to Russia

German Customs has issued a press release (actually dated 18 September but not spotted until now) reporting on an investigation and raids of several premises in the Aschaffenburg area.

The investigation by Essen Customs Investigation Office and the Würzburg Public Prosecutor’s Office relates to alleged exports of luxury cars to Russia valued at over €10 million.

As part of the raids evidence was collected, while cars valued at over €1.5m and bank accounts with over €1m were also seized.

October 11, 2024October 11, 2024 by Mark Handley

France – acquittal of ship’s captain charged with sanctions violations

In an earlier post we reported on the ongoing trial of the captain of the ship the “Baltic Leader”, who was being prosecuted in Rouen for alleged breaches of the EU’s Russian sanctions. French prosecutors were seeking a combined fine and confiscation of €16 million.

It is now being reported that yesterday the captain was acquitted of all charges.

Currently no further details are available.

October 11, 2024October 11, 2024 by Mark Handley

United Kingdom – 37 ongoing oil price cap investigations

The BBC is reporting the results of a Freedom of Information Act request it has made to OFSI.

The response itself is not currently on the website of either OFSI or HM Treasury.

The BBC is reporting the following statistics:

52 investigations opened since December 2022
15 of those have been concluded with no further action taken; and
37 of the investigations are ongoing.

As per our earlier post, in an earlier Freedom of Information response OFSI confirmed that as of April 2024 it had started 12 investigations of which 9 had been discontinued without action taken.

As such 40 new oil price cap investigations have been started since April 2024.

Since April six investigations have been concluded.