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.
We are today launching a new blog dedicated and focused on the regulatory and criminal enforcement of financial and trade sanctions across Europe – the EU, as well as countries such as Switzerland, the United Kingdom and Norway.
The entries on the page can be filtered by enforcing country, the year of enforcement, business sector, or the applicable sanctions regime. The posts are also fully text searchable.
The blog documents hundreds of enforcement actions in the period from 2017 to the present day in a total of 22 different European jurisdictions, as well as the existence of over 1,300 announced criminal or regulatory investigations which are current and ongoing across the continent.
These pages will serve as a repository for up-to-date enforcement statistics, including the cumulative of fines and penalties and the number of successfully-concluded enforcement actions.
Continue reading “The enforcement of sanctions across Europe – 2017 to the present: a new resource”
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.
The Latvian VDD has announced that it has carried out raids in Moscow House in Riga on 21 and 22 December with significant data and document seized.
A criminal case has been initiated against one individual.
It has been reported that Federal Prosecutors in Germany have applied to confiscate €720 million in frozen assets belonging to Russia’s National Securities Depository.
After the NSD had been designated it had sought to move the funds and made transfer requests to JP Morgan and Commerzbank which refused to proceed with the transfer. As such the prosecutors are seeking to have the funds treated as the proceeds of crime and so confiscatable under ordinary anti-money laundering rules.
The UK’s Office of Financial Sanctions Implementation has today published its Annual Review for 2022-2023.
The report includes the following regarding enforcement activity:
“As of April 2023, OFSI’s Enforcement Unit had 172 cases under live investigation, many of which are complex and remain ongoing.
In 2022-2023, OFSI recorded 473 suspected breaches of financial sanctions (excluding oil price cap and counter-terrorism breaches). This is a significant increase on the 147 cases recorded in 2021-2022. This increase was expected given the scale of increased Russia sanctions, and OFSI’s increased enforcement capabilities. This data refers to the year in which a suspected breach is recorded, rather than the year in which the potential breach activity occurred. Recorded breaches includes cases which are self-reported, reported by a third party, and those independently generated by OFSI.
Over the course of the financial year, OFSI issued 7 warning letters in response to confirmed breaches which OFSI did not consider warranted public enforcement action, and 2 monetary penalties. 51 cases were closed with no further action, 44 of which related to Russia related sanctions breach reports. OFSI does not in all cases provide its view of whether a breach occurred or not, although many suspected breaches recorded by OFSI are considered not to be breaches of financial sanctions following further investigation. A number of cases in this period were referred to other agencies, including criminal and regulatory authorities. OFSI does not provide further breakdowns on referrals to criminal authorities”.
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.
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.
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.
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.
