Lithuania – raids as part of investigation into sanctioned exports to Russia and Belarus

It is being reported (here and here) that Lithuania’s Financial Crime Investigation Service and the State Security Department, with coordinating assistance from the European Public Prosecutor’s Office, are undertaking an investigation into suspected breaches of the EU’s Russian and Belarus sanctions by Lithuanian, Russian and Belarus individuals.

It is alleged that those involved forged documents to obtain funding from the EU Space Agency, and that the money was then used (with other funds) by a company incorporated in Lithuania to obtain and export microchips, semiconductors, navigation systems, and other technical devices to Russia and Belarus.

In total 10 raids were conducted, and 5 individuals and one company are under investigation.

Estonia – arrest and pre-trial detention for sanctioned media offence

A court in Estonia has remanded an individual, Oleg Bessedin, in custody for two months while he awaits trial.

The prosecution is for a number of offences including allegedly breaching prohibitions in relation to the dissemination and broadcast of content from designated Russian media outlets under the EU’s sanctions.

The man denies the charges, but has been remanded due to perceived fight risk.

Finland – suspended sentence on conviction for dual-use exports to Russia

It is being reported, that after pleading guilty to charges of exporting dual-use goods to Russian in breach of the EU’s sanctions, a 20-year old student has been given a 14-month suspended sentence.

The student exported dual-use drones, laptops, computer processors, smartphones and laser rangefinders valued at nearly €74,000.

Further to our earlier post, two other accomplices were also arrested in May 2024 and have been investigated for exports valued at another €70,000.

As well as pleading guilty the student is said to have co-operated with the investigation. The outcome relating to the other two defendants is not yet known.

Switzerland – investigation into alleged spyware exports

As reported by GIR (behind a paywall) a decision by the Swiss Supreme Court has revealed an ongoing investigation by the Swiss Office of the Attorney General into alleged exports of spyware software to various countries in breach of Swiss export control laws.

The investigation relates to Andrea Gambazzi, and the company Thalestris Switzerland.

The judgment itself relates to whether documents seized as part of a raid by the authorities can, or cannot, be used as part of the investigation.

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

Germany – prosecution seeks 5 year jail term for sanctions violation ringleader

It is being reported that as part of an ongoing trial in Hamburg, that the Prosecutor’s Office is seeking a jail term of 5 years and 10 months for the main defendant. It is noteworthy that the Defence is seeking a jail term of 3 and a half years underlining the seriousness of the offending.

The alleged offending relates to the export of approximately €800,000 in electrical components and laboratory supplies.

There are four other individual defendants with the prosecution seeking shorter jail terms of suspended sentences for those.

The trial has been ongoing since April, and the verdict is expected shortly.

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.

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.

Finland – Customs investigation into suspected electronics exports to Russia

On Thursday Finland’s Customs announced details of an ongoing investigation into a suspected aggravated offence of breaching the EU’s sanctions. This is the most serious category of offence under Finnish law.

Customs are investigating a company from eastern Finland alleged to have sold electronic parts and components (semiconductors, microchips, processors and connectors) to Russia valued at approximately €2.7m.

The two main suspects are a father and son, with the son currently serving in the Russian army.

The products are alleged to have been shipped via several different routes including via other EU countries, Hong Kong, direct to Russia, and others seemingly collected in Finland.

A tax investigation is also under way.

Prior to 2022 the company’s business is said to have been dedicated to tourism and the sale of art.

France – TV regulator orders satellite provider to stop broadcasting sanctioned Russian channels

The French media regulator, Arcom, has issued an order to Eutelsat ordering it to cease the broadcasting of two channels owned or controlled by JSC National Media Group which is a designated person under the EU’s Russian sanctions.

The channels are STS and Kanal 5.

Earlier reports had suggested that Arcom might impose a fine on Eutelsat, but no fine was imposed.

Latvia – prosecutions brought against four for exports to Russia

It is being reported that Latvia’s State Security Service has referred four individuals for prosecution for alleged exports of satellite communications equipment for the Russian military in breach of EU sanctions and other Latvian laws.

The investigation is ongoing and it is reported that other individuals are suspected of being involved.

The goods exported were Starlink Mini satellite communication systems.

© 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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