Cyprus – investigation into potential attempted sanctions circumvention

It has been reported today that the Company Registrar in Cyprus, alongside the Cyprus Bar Association, are investigating an instance of possible Russian sanctions breaches.

The investigation relates to allegations that two days after additions to the OFAC SDN list a Cypriot company newly-filed documents purporting to show corporate rearrangements dating back several years which is accurate and reliable would remove the company from the impact of the US listing.

It is unclear whether the investigation relates to any breaches of the EU’s sanctions.

 

Germany – two charged for exporting drone components in breach of Russian sanctions

The Federal Prosecutor’s Office in Germany has charged two individuals (named as Waldemar W. and Natalie S.) with the export of electronic drone components to Russian in breach of EU sanctions.

The components were first imported into Germany and then exported via Kyrgyzstan and Hong-Kong. The charges relates to 54 separate shipments up to March 2023. The shipments date from both before and since the large-scale invasion of Ukraine.

The total value of the components is stated as €875,000.

Waldemar W was the managing director of two involved companies incorporated in Saarland wand Natalie S managed a company in Baden-Württemberg. It is alleged that suppliers were provided with false end-user information which purported to confirm that the goods were to remain in Germany.

Waldemar W. has been in custody since 9 March 2023. Natalie S. was in custody previously but was subsequently released.

 

Netherlands – three arrested on suspicion of circumventing Russian sanctions

The Dutch FIOD has today announced three arrests as part of an ongoing criminal investigation into suspected  exports in circumvention of the EU’s trade sanctions against Russia.

The individuals are two men from Diemen and a woman from The Hague. The men were both directors of a company founded in 2017, and the arrested woman was an employee.

UPDATE: it is now being reported that the Dutch company involved is ETW-Tekhnologiya and that the company’s founder, Mikhail Volovik,  is being sought but has not yet been arrested

The goods are described as technological and laboratory goods capable of military use – i.e. dual-use goods.

Searches and witness interviews have taken place in the Netherlands, Germany, Latvia, Lithuania and Canada.

Finland – five charged with EU Russian sanctions offences

It has been reported that the Finnish authorities have charged five individuals with sanctions offences.

The allegations relate to the export of drones to Russian in breach of EU sanctions.

The first defendant is Gabriel Temini who is the CEO of the Finnish companies Luminor and Siberica.

Three employees of Siberica have also been charged as well as an employee of a freight forwarding company.

The charges are denied.

Trial is scheduled to commence on 26 January 2024.

Romania – company fined and €2.9 million profits confiscated

An Advocate-General’s opinion in Case C-351/22 before the Court of Justice has revealed details of a not-previously publicised enforcement action from 2020 in Romania, by which the company Neves 77 Solutions SRL was administratively fined approximately €6,000 and had gross profits of €2.9 million confiscated.

The company had brokered a transaction whereby radio sets manufactured in Russia were sold by a Ukrainian company to an Indian company.

The question which came to be addressed by the Advocate-General was whether the confiscation of gross profits was compatible with fundamental principles of European law including whether it was a proportionate abrogation of the right to property. The Advocate-General’s opinion is that such confiscations are not a breach of European law.

Latvia – raids and arrests for dual-use sanctions investigation

The Latvian State Security Service (VDD) has today announced a series of six raids and two arrests in Riga which took place on 4 December 2023 in relation to a criminal investigation into a Latvian company suspected of exporting electronic components to Russia.

The goods are reported to have been valued at €500,000.

The company was not named and nor were the individuals.

Netherlands – arrests and raids regarding Russian sanctions

It has been reported today that the Dutch authorities, after a tip-off from unnamed US “agencies” have conducted searches at homes and business addresses in Sluis and Rotterdam.

Related search and arrests took place in the Belgium (see our related post) at the same time, and in total across both countries six have been arrested.

The allegations relate to the export of products and technology to Russia.

Belgium – raids and arrests for Russian sanctions

It has been reported today that the Belgian authorities, after a tip-off from unnamed US “agencies” have conducted searches at homes and business addresses in Knokke-Heist and Eeklo.

The Belgian government announcement is here.

Related search and arrests took place in the Netherlands (see our related post) at the same time, and in total across both countries six have been arrested, four of whom were arrested in Belgium

The allegations relate to the export of products and technology to Russia.

Finland – charges coming for 6 for Russian sanctions breaches

It has been reported today that Finnish Customs are preparing to charge six with Russian sanctions offences.

The activities relate to two Finnish companies suspected of exporting microcontrollers and semi-conductors valued at more than €600,000 to Russia, as well as nearly 3,500 drones value at over €2 million.

The investigation is said to have also involved the authorities from the Netherlands, the UK, the US, as well as Europol and Finland’s Security and Intelligence Service.

© 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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