France – seizure of Russian shadow fleet vessel and arrest of captain

It has been widely reported (e.g. here and here) that the French military boarded and seized control of an oil tanker reputed to to be part of the “shadow fleet”.

The vessel, the “Boracay” has been sanctioned by the EU and the UK. It is alleged that the crew failed to provide information to authorities on the nationality of the vessel or otherwise comply with orders.

It has now also been reported that the vessel has now continued on its voyage and the captain has been released.

Netherlands – company convicted of sanctioned exports ordered liquidated

Further to our earlier post from October 2024 reporting that a company had been convicted of exporting prohibited aircraft parts to Russia and fined €165,826, a judgment published on 5 September 2025 dealt with an application to liquidate the company by the Public Prosecution Service.

The company in question has now been named as Jet Air Equipment BV.

The Gelderland Court has ordered that the company be declared prohibited and that a liquidator be appointed for the dissolution of the company. The company will have the ability to make submissions on the identity of the liquidator, but the court reserved the right to make the appointment itself.

In addition an unnamed company director has been barred for 3 years from serving as a company director.

An application to have all the assets of the company be distributed to the state was denied.

The Dutch courts have previously ordered the liquidation of a convicted company.

Netherlands – declination for export in breach of Iran sanctions

A civil judgement from the Amsterdam Court of Appeal has revealed the outcome of an investigation of a breach of the EU’s Iran sanctions by the Dutch authorities.

The company in question, Air Cargo Consultants BV, had acted as freight forwarder (but not the seller) for eight shipments of aircraft engines to Iran starting in 2018.

The export of these parts to Iran became newly prohibited in 2023 under EU regulation 1529/2023. The products were also barred from export to Iran under US sanctions.

On 1 October 2024 Dutch customs stopped an attempt to export a ninth aircraft engine, based on a suspicion that the products were prohibited from export to Iran under the EU’s sanctions.

On the same day that the shipment was stopped the freight forwarder self-reported all nine exports to the US authorities, namely BIS, the Office of Export Enforcement and OFAC.

The civil judgment reports that in these circumstances the Dutch authorities declined to prosecute the freight forwarder but issued a warning that any further infractions would be prosecuted.

It is unclear from this judgment what, if any action, is being taken against the seller of the engines.

Lithuania – Customs raids and arrests for sanctioned exports in conjunction with raids in Portugal and Bulgaria

On Saturday Lithuania’s Customs issued a press release announcing raids on a company based in Kaunas, and associated residential premises, with 11 people (employees, company managers, as well as drivers) detained and a dozen tons of equipment (valued at around €2 million) seized.

It is alleged the company was exporting to Russia via Bulgaria and Turkey based on a fictitious customer in Portugal. Contemporaneous raids were conducted in Bulgaria to seize a shipment that had already left Lithuania, and in Portugal at the premises of the Portuguese customer.

The operation was coordinated by Eurojust and Europol and with assistance from the Portuguese authorities.

The exports are described as “water treatment equipment (dosing stations, large industrial water filters (osmosis), etc.) and their components (various pumps, filters, membranes)”. The press release adds that the products were specifically designed for the Russian customer.

Germany – 5 year sentence for and confiscation of c. €5m for sanctioned cars exports to Russia

As first reported in Global Sanctions, and as per a press release by German Customs, the Marburg Regional Court on 8 July has sentenced an individual to 5 years in jail for exporting luxury cars to Russian breach of the EU’s sanctions.

The man was convicted of 71 separate counts.

The court also confiscated approximately €5m as the gross proceeds of the cars sales.

Netherlands – two sanctions judgments: i) individual given 3 years prison sentence; and ii) confiscation of €1m in unlawful profits

The Dutch courts have published two sanctions judgments.

In the first case, the District court of Rotterdam has sentenced an individual to three years in jail.

The individual was convicted for providing technical assistance to a person in Russia or for use in Russia of different computer files containing information on the manufacture of microchips. The files were shares by Google Drive and Telegram between January 2023 and August 2024.

The defendant was acquitted of charges of physically taking similar files to Russia on USB sticks.

On sentencing the judgment stated:

Providing advice to and sharing technology with Russia is extremely serious. It can contribute to strengthening military or strategic capabilities of that country, which has an impact on Ukraine and can indirectly affect international security and stability. It is therefore a serious offence. … The nature and seriousness of the facts justify a prison sentence of considerable duration. The fact that the files would contain outdated information is irrelevant because this information can be of great value to a country with a (much) lower level of knowledge. It must be prevented that a country at war can benefit in any way from advanced technological knowledge. After all, for that reason, an extensive package of sanctions has also been agreed against Russia, among others“.

In the second case, the District Court of Amsterdam has issued an order confiscating €1,013,956.00.

The unnamed corporate defendant had been provided goods and services in relation to the construction of the Kirch Bridge, and had been convicted on 28 November 2024 (our previous post here), with a fine of €120,000 imposed.

The court calculated that the gross revenue obtained in breach of sanctions was €2,711,085, but allowed certain costs including internal time incurred and the cost of insurance resulting in a final confiscation of €1,013,956.

The effect of this is that revenue of nearly €1.7m obtained in breach of the EU’s sanctions was retained by the convicted company.

Germany – arrests and raids related to luxury car exports to Russia

The Austrian TV station TV21 has broadcast a story (on YouTube in English) reporting on raids and searches by the Hannover Customs Office in North Rhine-Westphalia and Lower Saxony on behalf of the Bielefeld Public Prosecutor’s Office.

Three individuals were arrested.

As well as trading in untaxed cigarettes, it is suspected that the group were responsible for the prohibited export of 100 cars to Russia via third countries in breach of the EU’s sanctions.

Netherlands – arrests and raids in sanctions investigation into alleged supplier to the “shadow fleet”

The Dutch FIOD has issued a press release regarding the arrest of four individuals and the launch of a criminal investigation into those individuals and an unnamed company operating in the Rotterdam area.

The individuals and company are suspected of being “involved in prohibited supplies or support of ships that are part of the so-called Russian shadow fleet” in breach of the EU’s Russian sanctions.

Raids and searches were carried out at four homes and the company’s premises.

Spain – sanctions-related investigation into origins of imported diesel

It has been reported that the Spanish National Anti-Fraud Investigation Office, and competition authorities, have opened an investigation into the importation of diesel to Spain from Turkey and Morocco.

The suspicion being investigated is whether the diesel actually originates from Syria, Russia and/or Iran.

The investigation is reported to have been commenced in late 2024.

As further reported: “Several of the companies that were accused of bringing oil from Morocco due to their price advantage as they are of Russian origin in 2023 have either been disqualified or are currently involved in legal proceedings for fraud“.

Italy – seizures against Iranian company associated with Russia

It has been reported (here and here), that in early June the Italian police conducted seizures in Milan against the “Iranian” company Irital Shipping Lines.

The seizures involved assets of over €1m.

The reported reason was “Iran’s military support for Russia’s aggression against Ukraine”.

No public statement has been made by the Italian authorities, and it is unclear what is the precise nature of the allegations.

© 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.

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