European Sanctions Enforcement

April 12, 2024 by Mark Handley

Poland – sanctions investigation commenced into state-controlled oil trading company

After first being reported by Polish radio station Radio Zet, it is now being reported in the press that the Polish Special Services has commenced an investigation into whether the Swiss oil trading subsidiary of a state-controlled oil company has breached the EU’s Russian sanctions in relation to oil.

The Polish parent company is Orlen, which is 49% owned by the Polish state, and the Swiss subsidiary is Orlen Trading Switzerland.

It is alleged that the Swiss subsidiary was incorporated in Switzerland in late 2022 ahead of the relevant changes to EU sanctions which came into effect in early 2023 as a means of continuing to purchase and trade in oil of Russian origin.

The companies are reported as having denied the allegations.

April 11, 2024 by Mark Handley

Latvia – investigation into bunkering vessel refueling Russian “shadow fleet”

A vessel owned by a Latvian company is providing bunkering (i.e. refueling) services to the Russian “shadow fleet” in the Baltic sea off the coast of Gotland in Sweden.

A spokesman for the Latvian Foreign Ministry has stated that an investigation is now underway to see if the Latvian company is breaching or circumventing EU sanctions, in particular whether the fuel being supplied is of Russian origin.

The Latvian company, Fastbunkering, denies breaching sanctions.

It is noteworthy that just two days ago the Swedish authorities were reported as having closed an investigation into these same possible breaches of sanctions.

A Swedish prosecutor was reported as having stated: “I have made the assessment that it is not worth requesting legal aid from Latvia because it is not expected to lead to a higher penalty than a fine“.

April 11, 2024 by Mark Handley

Cyprus – more than 40 ongoing Russian sanctions investigations and first indictments expected soon

The Cypriot authorities have more than 40 ongoing criminal investigations related to alleged breaches of the EU’s Russian sanctions.

It is being reported that yesterday the current status of “all open cases exceeding 40 were reviewed” by the Law Office and the state’s Attorney General, with the Office for Economic Crime Investigation.

It is also being reported that for the completed investigations “indictments will be prepared to initiate criminal prosecutions in court”.

April 10, 2024 by Mark Handley

Lithuania – Customs Department launches investigation into exports to Russia

Following press reporting into allegations that the Viciūnai Group of companies were exporting sanctioned goods to Russia, it is now being reported that the Lithuanian Customs Department has commenced a pre-trial investigation.

The allegations include that dual use and “battlefield” goods were being exported to a factory in Kaliningrad operated by a related company.

It is reported that the company has confirmed the fact of the exports, but claims that it was not aware that the goods in question (which includes ball bearings, semi-conductors, electrical components and other goods) were subject to sanctions.

April 9, 2024 by Mark Handley

United Kingdom – charges to two further individuals added to existing prosecution

Further to our earlier post, regarding the UK’s National Crime Agency charging Dmitry Ovsyannikov with multiple counts of breaching the UK’s Russian sanctions, following a hearing in London it is now apparent that the National Crime Agency has also charged Ekaterina Ovsiannikova (the first defendant’s wife) and Alexei Owsjanikow, (the second defendant’s brother).

As per Spotlight on Corruption, a further hearing is listed for 28 June to hear application by the defendants to dismiss the charges.

The hearing, as reported by Global Investigations Review (behind a paywall), on Monday was largely procedural and dealt with issues like bail terms. The defendants have yet to enter a plea.

April 5, 2024April 5, 2024 by Mark Handley

Germany – Ministry of Economic Affairs calls for investigation into alleged sanctions breaches relating to Mariupol reconstruction

The German Ministry of Economic Affairs and Climate Change is being quoted in the press as having called for an investigation by the relevant authorities into allegations that two German companies may be breaching the EU’s sanctions by providing material for the rebuilding of the occupied city of Mariupol.

The companies, Knauf and WKB Systems GmbH have both issued statements saying they comply with relevant sanctions.

The call for an investigation follows reports of the supply of construction material first published in Monitor.

April 5, 2024 by Mark Handley

Cyprus – sanctions investigation into purported share transfer by Mordashov in the “final stages”

Further to our earlier post there has been an ongoing investigation in Cyprus in relation to the alleged transfer of over $1 billion in shares by Alexey Mordashov in breach of the asset freeze imposed upon him by the European Union.

It is now being reported that the Cypriot investigation has reached its “final stages”.

The report gives no indication of the outcome of the investigation.

The allegations relate to transfers of the shares in the tourism operator Tui.

April 4, 2024 by Mark Handley

Ireland – investigation launched into alleged breaches of EU and UN Libyan sanctions

The Irish Department of Enterprise, Trade and Employment has launched an investigation into alleged breaches of both UN and EU sanctions against Libya first reported in the Irish Times.

It is alleged that former members of the Irish Defence Forces provided military training and material to forces of Khalifa Haftar’s Libyan National Army in breach of relevant arms embargoes.

It is alleged that the initial contract was entered into by an Irish company co-owned by Danny Cluskey, Darren Kelly and Nigel McCormack, and that the contract was then switched to a Dubai-based company (SOF Training).

April 4, 2024 by Mark Handley

United Kingdom – Gambling Commission fines two operators citing sanctions compliance failings

The UK’s regulator for the gambling sector, the Gambling Commission has issued a press release recording fines of £343,035 against Hillside (UK) Gaming ENC and £239,085 against Hillside (UK Sports) ENC.

Both companies operate under the Bet365 brand.

The fines in part relate to social responsibility failings, and partly to financial crime compliance failings including “failing to undertake financial sanctions checks on new customers prior to their first deposits”.

April 2, 2024 by Mark Handley

Latvia – criminal investigation into helicopter sale discontinued

It is being reported that the Latvian State Security Service (the VDD) has discontinued a criminal investigation started in November 2023 into the sale of a helicopter by a company indirectly co-owned by the designated person Petr Aven .

The sale had been reported to the VDD by a court-appointed bailiff on suspicion that the sale (which took place as part of an insolvency proceeding of the helicopter owning company) may be being used as a tool to circumvent the relevant asset freezes imposed by the EU.

The investigation included the questioning of a number of witnesses, and the freezing of the sale proceeds.

The VDD has concluded that the insolvency was proper, that the loan agreement which funded the helicopter purchase pre-dated the imposition of sanctions, and that the debts of the company could be discharged from the sale proceeds