Belarus – European Sanctions Enforcement

September 24, 2025September 24, 2025 by Mark Handley

Poland – 20 people detained for alleged luxury car exports to Russia and Belarus

Poland’s Central Bureau of Investigation of the Police has issued a press release relating to the arrest of 20 people for alleged involvement in a scheme to export of approximately 600 luxury cars to Russia and Belarus in breach of the EU’s sanctions.

The scheme is said to have involved a sequence of sales within the EU, followed by sales to customers in third countries such as Kazakhstan and Azerbaijan, followed by a further transfer to Belarusia or Russia.

Several of the defendants are being detained in custody while the investigation continues.

More than PLN 10m in bank accounts have been frozen as part of the investigation.

September 22, 2025September 22, 2025 by Mark Handley

Poland – updated statistics on the 42 imposed sanctions fines

With grateful thanks to the Ministry of Finance and the Economy in Poland for the provision of the information, this blog can provide an up-to-date summary of the scale of financial penalties imposed by the Polish authorities in relation to Russian and Belarusian sanctions violations.

These figures relate to the period up to 28 August 2025.

In total the Polish authorities have imposed 42 financial penalties, broken down on the following basis:

24 penalties in relation to breaches of EU Regulation 833/2014, with total fines of PLN 6,850,949 (just over €1.6m);
6 penalties for breaches of EU Regulation 269/2014, with total fines of PLN 911,515 (just over €213,000);
10 penalties for breaches of the Polish Sanctions Act of 13 April 2022, with total fines of PLN 18,886,441 (€4.42m);
1 penalty under EU regulation 765/2006 in relation to Belarus, with a fine of PLN 7,367 (€1,727); and
1 penalty relating to both Regulations 833/2014 and 765/2006, with a fine of PLN 36,272 (€8,506).

This updates the statistics previously published on this blog from July 2024.

It shows that Poland has imposed a 18 fines since that time. Of those 12 were under Regulation 833/2014, four were under Regulation 269/2014, and the two smaller fines relating to Belarus have also been imposed since July 2024.

August 27, 2025August 27, 2025 by Mark Handley

Latvia – investigations into sanctioned Belarusian urea imports

It is being reported that the Latvian authorities have been conducting multiple investigations into suspected imports of urea from Belarus in breach of the EU’s sanctions.

The investigations are reported to be focussed on four Latvian companies and were commenced in July.

After a referral from the Customs Administration the VID Tax and Customs Police Department initially declined to prosecute, but that decision is now the subject of an appeal brought by the Customs Administration and Latvia’s FIU.

May 21, 2025May 21, 2025 by Mark Handley

Poland – seizure of 5 tons of aviation tyres bound for Russia/Belarus

Poland’s National Tax Administration has issued a press release, announcing the seizure of 5 tons of aviation tyres.

The discovery was made through a routine inspection of a truck by the Lublin Customs and Tax office.

The declared goods were automobile tyres. The sender of the tyres was an unnamed company in Spain, and the declared recipient was said to be in Azerbaijan.

The goods were detained and criminal proceedings have been instituted.

May 13, 2025May 21, 2025 by Mark Handley

Poland – multiple raids and arrests for suspected import of timber in breach of Russia and Belarus sanctions

Poland’s National Tax Administration yesterday issued a press release detailing raids and arrests in three provinces.

The three arrested individuals have been charged and are in pre-trial detention. They are suspected of importing birch plywood from Belarus and Russia in breach of EU sanctions.

The Tax Administration has conducted a number of similar investigations in recent months, which have not previously been included in this blog:

24 April 2025 – The Pomeranian branch of Poland’s National Tax Administration has conducted raids in Gdynia. Thirty pallets of timber suspected to have been imported from Belarus and Russia were seized.

9 April 2025 – The Pomeranian branch of Poland’s National Tax Administration has conducted inspections of timber purportedly imported from Tunisia at the Baltic Container Terminal in Gdansk, and seized over PLN 1 million in timber on suspicion that it was imported from Belarus and Russia in breach of EU sanctions.

28 February 2025 – The Lublin branch of the National Tax Administration has seized 1800 pallets of plywood suspected of being imported from Belarus and Russia via China and Kazakhstan. The press release adds that 15 sets of proceedings are being prepared as a result of the seizures valued at PLN 3.2m.

November 2024 – raids were conducted in seven provinces in relation to an ongoing investigation into suspected imports of timber from Belarus and Russia in breach of Eu sanctions.

February 6, 2025February 6, 2025 by Mark Handley

Lithuania – sanctions raids, arrests and seizures related to trucking companies

It is being reported that the Lithuanian Customs Criminal Service has conducted raids at multiple addresses in Vilnius and Rudamina, has arrested four individuals (2 Belarus nationals and 2 Lithuanian nationals), and seized 33 vehicles valued at €1.5 million.

The vehicles are 17 trucks, 15 semi-trailers and a mini-bus, which are said to have been involved in alleged trade with Russia and Belarus in breach of the EU’s sanctions.

The first round of raids were conducted on 29 January with further raids since then.

January 23, 2025November 3, 2025 by Mark Handley

Germany – raids and arrests of suspected exporters of luxury cars to Russia and Belarus

It is being reported that on 16 January raids were carried out at six addresses in Ludwigshafen, Schifferstadt and Mannheim and a 53-year old was arrested on suspicion of exporting over 150 luxury cars to Russia and Belarus valued at more than €7,500,000.

Cash and cars valued at more than €500,000 were seized and accounts frozen.

The same article reports on another case from November 2024 (also reported here), in which a 26-year old was arrested and detained on suspicion of exporting 30 luxury cars to Russia valued at around €3,500,000.

The Customs press release is here.

January 22, 2025September 22, 2025 by Mark Handley

Finland – updated statistics on its 909 Russian trade sanctions investigations

As an update to our previous post on the 900 or so sanctions investigations started by Finnish Customs since the start of 2022, we can provide a more detailed breakdown of providing figures for these investigations.

The blog is happy to acknowledge the information and assistance provided by Finnish Customs.

To explain the figures below, under Finnish law sanctions offences are divided into three categories:

Petty regulation offences – punishable only by fines;
Regulation offences – punishable by fine or imprisonment for a maximum of 2 years; and
Aggravated regulation offences – punishable by imprisonment of at least 4 months and not more than 4 years.

Against that background, Finnish Customs has provided a break down over time of when the investigations were started and the category of offending that was being investigated.

Year	Petty Regulation Offence	Regulation Offence	Aggravated Regulation Offence	Total
2022	104	158	44	306
2023	354	86	64	504
2024	5	59	35	99
Total	463	303	143	909

The drop off relating to petty regulation offences in 2024 is to be attributed to the closure of all crossings along the land border with Russia, as most of the examples in that category had been attempts to export prohibited goods by individuals in cars and other vehicles.

December 9, 2024December 10, 2024 by Mark Handley

Denmark – sanctions enforcement activity 2022-2024

Presenting a webinar this morning made me aware that this blog had missed a number of stories relating to Danish sanctions enforcement.

I have endeavoured to rectify that gap with a number of posts filling gaps from 2022 through to early 2024. Because I have back-dated the posts so that they appear in the correct sequence it made sense to collect them into a properly new post to highlight the additions.

Importantly, between February 2022 and August 2023 a total of 98 investigations were opened, with 16 referred to the police. In addition the police have charged a company and two individuals in relation to one particular case.

conclusion of a Danish FSA investigation into a payment services provider in January 2024: https://blogs.duanemorris.com/europeansanctionsenforcement/2024/01/19/denmark-danish-fsa-concludes-investigation-into-payment-services-provider/
a company and two individuals charged with sanctions offences relating to alleged arms exports to Russia in January 2024: https://blogs.duanemorris.com/europeansanctionsenforcement/2024/01/12/denmark-three-charged-in-relation-to-alleged-arms-exports-to-russia/
45 investigations opened between January and August 2023, of which 23 remained open and 2 had been referred to the Police: https://blogs.duanemorris.com/europeansanctionsenforcement/2023/08/16/denmark-45-sanctions-investigations-opened-so-far-in-2023/
two Russian designated persons referred to the Police by the Danish Business Authority in January 2023: https://blogs.duanemorris.com/europeansanctionsenforcement/2023/01/25/denmark-two-further-sanctions-investigations-referred-to-the-police/
12 criminal cases opened by the police and 34 investigations commenced by the Danish Business Authority between February 2022 and October 2022: https://blogs.duanemorris.com/europeansanctionsenforcement/2022/10/26/denmark-12-criminal-investigations-for-sanctions-breaches-opened/

December 5, 2024December 5, 2024 by Mark Handley

Germany – sanctions investigation into alleged exports to Belarus by politician’s company

It is being reported that a German customs investigation has been commenced into the business affairs Jörg Dornau who is an MP in the Saxon state parliament.

It is alleged that he arranged for the export of machinery to Belarus in breach of EU trade sanctions.

It is alleged that the goods were first sent to Kazakhstan before then being on-shipped to a company in which the politician has interests in Belarus called Zybulka-Bel.

The press article mentions that before any prosecution could be brought the MP’s immunity would need to first be lifted.