Germany – two Customs investigations into Russian imports/exports

Two previously missed investigations from German customs into luxury car exports to Russia:

A. December 16, 2025

After commencing an investigation in December 2024, and raids conducted in May 2025, German Customs obtained an asset freeze over €16.5m.

The investigation is into a 41 year-old German-Moldovan national suspected of exporting 236 vehicles to Russia valued at €18.86m.

Further searches were conducted at properties in Ger and Teuchern in December 2025.

B. February 25, 2026

Raids and property searches were carried out in Hamburg relating to a company’s managing director suspected of more than 900 prohibited imports from Russia valued at over €4m.

The press release notes that “due to the ongoing investigations, no statement can yet be made about the type of goods”.

    Belgium – €10m payment and rectifying infractions required to obtain release of seized shadow fleet tanker

    Further to our earlier post regarding the Belgian seizure of the tanker, the Ethera, it is now being reported that 45 infractions have been identified in relation to the flag status and condition of the vessel.

    It is also being reported that these infractions will need to be rectified before the vessel will be released and that a €10m payment will need to be made. Different reports (here, here and here) describe this payment as a bond, a bail payment, or a fine.

    The blog’s 700th post – sanctions enforcement milestones reached

    With today’s post on convictions in Germany, the blog has reached the milestone of 700 posts.

    The post also takes European Sanctions Enforcement over several other milestones:

    • The €20m confiscated is Europe’s seventh largest sanctions fine/confiscation since 2017. All but one of those from the UK were fines imposed by the Financial Conduct Authority.

    • There has now been more than €500m in fines, penalties or confiscations since 2017.
    • More than a century of jail time has been handed out since 2024, and Germany alone has seen sentences of more than 70 years of jail since 2017.

    Enforcement across Europe is trending upwards.

    Germany – convictions, €20m confiscation and 6 years in jail for luxury car exports to Russia

    German Customs has announced the result in a criminal prosecution of two individuals charged with exporting 111 luxury cars to Russia in breach of EU sanctions.

    See our earlier post relating to the raids conducted in 2024.

    The vehicles were armored and classified as luxury under the EU sanctions.

    One defendant pleaded guilty ahead of the trial, Inna W, and was given a 2-year suspended sentence. The main defendant, Andreas M, pleaded guilty mid way through the trial. He was given a six year jail term and has been in detention since his arrest in November 2024.

    The defendants had further plans for the export of another 400 cars valued at €40m.

    The evidence indicated an extensive procurement network of shell companies for purchasing the vehicles before export. Customers for the vehicles included various Russian state agencies and state-owned corporations.

    The sentence included the confiscation of “approximately €20m” as the proceeds of crime said to be from the individuals and the companies involved.

    Denmark – container vessel detained for unclear flag status

    The Danish Maritime Authority detained the container vessel the Nora on 20 February.

    When the vessel first dropped anchor in Danish waters it was flying a Comorian flag. It is reported that upon investigations by the Danish government the Comorros registry then denied that the vessel was flagged there, leading to the Danish detention of the vessel.

    The vessel, sanctioned by the US under its Iran sanctions and formerly named the Cerus, is reported to now be flying the flag of Iran. The same vessel is sanctioned by Ukraine under its Russian sanctions

    Belgium – criminal investigation opened after North Sea seizure of tanker “Ethera”

    On Saturday night a combined operation of the Belgian and French military (see here and here) saw the seizure of the sanctioned “shadow fleet” tanker the Ethera in the North Sea.

    The tanker has since been brought to Zeebrugge .

    It is being reported that a criminal investigation has been opened, and it is alleged that the vessel was falsely claiming to have a Guinea flag.

    The vessel’s captain, reported as a Russian national, has been questioned.

    Portugal – Public Prosecutor opens 26 investigations into Russian sanctions breaches

    It is being reported that the Portuguese Public Prosecutor’s Office has opened 26 criminal investigations into possible Russian sanctions breaches since the start of the full-scale war in Ukraine.

    No further information is provided as to the nature of the alleged offending or the current state of progress of those investigations.

    It is also reported that the Security Intelligence Service (SIS) has “been monitoring and assessing presence in Portugal of elements connected, directly or indirectly with Vladimir Putin’s regime”.

    Switzerland – FINMA revokes licence of merchant bank for AML and sanctions compliance failures

    The Swiss financial services regulator has put out a press release announcing its decision, taken several weeks ago, to revoke the licence of MBaer Merchant Bank AG for AML and sanctions compliance failings.

    Initially the bank appealed this decision.

    In the wake of the US regulator FinCEN announcing that it proposed to name the bank as a “financial institution of primary money laundering concern”, the bank has withdrawn the appeal against FINMA’s decision, and a liquidator has now been appointed to oversee the bank’s liquidation.

    United Kingdom – Office of Trade Sanctions Implementation has “about five cases close to conclusion”

    In oral evidence given yesterday to the UK Parliament’s Business and Trade Subcommittee on Economic Security and Export Controls, the Minister for Trade stated (at around 16:18 in the video) in relation to the enforcement efforts at the Office of Trade Sanctions Implementation:

    We have got about five cases which are quite close to conclusion and could lead to substantial measures being taken. … Significant numbers of cases have been either closed because there is nothing to pursue, or have been referred directly to HMRC or soe other government departments to be able to take further action. … I think we have got pretty effective enforcement of our sanctions regime. I would argue that its more effective than any other country that I have yet seen. …

    We’ve had 185 potential breaches that were reported, 5 as I say are at a late stage, 117 closed, 57 reported to HMRC“.

    HMRC gave evidence that in 2025 it had had 42 referrals from OTSI, of which 19 are still under review, 8 concluded with no further action taken, 9 cases were linked to pre-existing HMRC investigations, 1 case was referred to the National Crime Agency, and 5 cases that were subject to a “de-confliction” process between OTSI and HMRC to work through enforcement responsibility.

    HMRC also stated that it currently had 21 live criminal investigations for export control offences (note that as per an earlier previous post HMRC very recently stated it had 51 investigations in 2024/2025).

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    The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

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