Belgium – European Sanctions Enforcement

November 15, 2024November 28, 2024 by Mark Handley

European sanctions enforcement: the custodial sentences

Although one of the filters on this blog is “custodial sentence”, I thought it might be helpful to collect all the examples in one place.

As such, here is the full list of custodial sentences that have been imposed across Europe for sanctions offences since 2017. Please note this excludes suspended sentences.

2017:

Netherlands – 2 years: https://blogs.duanemorris.com/europeansanctionsenforcement/2017/03/14/netherlands-two-year-sentence-for-breach-of-al-qaida-sanctions/
Netherlands – 19 years (although this sentence included numerous other offences): https://blogs.duanemorris.com/europeansanctionsenforcement/2017/04/21/netherlands-19-year-jail-term-upheld-on-appeal/
Italy – 2 years: https://blogs.duanemorris.com/europeansanctionsenforcement/2017/05/03/italy-two-year-sentence-for-arms-exports-to-libya-and-iran/
Italy – two individuals given 3 years and 8 months and 3 years and 6 months respectively: https://blogs.duanemorris.com/europeansanctionsenforcement/2017/07/13/italy-sentences-for-arms-exports-to-iran-and-libya/
Netherlands – 16 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2017/09/04/netherlands-fine-and-custodial-sentence-imposed-for-breach-of-iran-sanctions/

2018:

United Kingdom – 2.5 years: https://blogs.duanemorris.com/europeansanctionsenforcement/2018/11/22/uk-three-convicted-of-exporting-military-goods-to-iran/

2019:

Belgium – 12 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2019/02/07/belgium-convictions-for-breaching-syrian-sanctions/
Netherlands – two individuals given 1 month each: https://blogs.duanemorris.com/europeansanctionsenforcement/2019/02/18/netherlands-two-companies-and-three-individuals-convicted-of-iran-exports/
Netherlands – 12 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2019/11/05/netherlands-conviction-for-breach-of-isis-sanctions-2/

2020:

Germany – 7 years: https://blogs.duanemorris.com/europeansanctionsenforcement/2020/01/09/germany-seven-year-sentence-for/

2021:

Germany – 3 years and 9 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2021/03/04/germany-convictions-and-fines-for-russian-exports/

2022:

Netherlands – 6 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2022/02/04/netherlands-6-month-custodial-sentence/
Netherlands – 1 year and six months: https://blogs.duanemorris.com/europeansanctionsenforcement/2022/06/28/netherlands-18-month-sentence-for-exports-to-iran/
Netherlands – 2 years and 6 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2022/08/31/netherlands-30-month-custodial-sentence-for-breach-of-isis-sanctions/
Germany – 1 year and 7 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2022/11/17/germany-conviction-for-importing-timber-from-myanmar-referred-to-cjeu/

2023:

Germany – 5 years: https://blogs.duanemorris.com/europeansanctionsenforcement/2023/08/30/germany-conviction-for-exporting-drone-parts-to-russia/
Netherlands – 1 year and 6 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2023/11/01/netherlands-custodial-sentence-and-corporate-fine/

2024:

Finland – 40 days: https://blogs.duanemorris.com/europeansanctionsenforcement/2024/02/14/finland-conviction-of-russian-national-for-breach-of-the-eu-travel-ban/
Netherlands – 4 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2024/04/19/netherlands-four-month-prison-sentence-for-breach-of-isis-sanctions/
Germany – 6 years and 9 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2024/07/18/germany-two-individuals-convicted-of-electronics-exports-to-russia/
Netherlands – 4 years: https://blogs.duanemorris.com/europeansanctionsenforcement/2024/09/12/netherlands-conviction-for-breach-of-isis-sanctions-upheld-by-court-of-appeal/
Netherlands – 2 years and 8 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2024/10/07/netherlands-two-years-and-eight-months-sentence-for-exporting-sanctioned-goods-to-russian-airlines/
Germany – 7 years: https://blogs.duanemorris.com/europeansanctionsenforcement/2024/11/08/germany-seven-year-sentence-for-exports-of-military-and-dual-use-goods-to-russia-and-confiscation-of-profits/
Netherlands – 1 year and 3 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2024/11/11/netherlands-conviction-and-confiscation-for-exporting-sanctioned-goods-to-russian-companies/

Overall the figures are dominated by the Netherlands and Germany with approximately 68 of the 80 years of sentences between them. Indeed, as the graph below demonstrates, other than Finland’s 40-day sentence for breaching a travel ban, the Netherlands and Germany are the only European countries to have sent someone to prison for sanctions offences since 2019.

April 22, 2024 by Mark Handley

European Sanctions Enforcement – milestone of over 2000 announced and active investigations reached

With the recent news that Finland has increased the number of its ongoing investigations, Europe (meaning the EU, the UK, Switzerland, etc) has reached the milestone of over 2,000 ongoing and public sanctions enforcement investigations being undertaken by regulators and prosecutors.

No doubt there are other investigations which are ongoing in the countries shown on the graph, and no doubt there are investigations ongoing in countries not shown and which remain confidential.

How many of these will be dropped due to inconclusive evidence or exculpatory evidence, and how many will lead to a conviction or fine or acquittal is impossible to say.

It is, without question, an unprecedented level of enforcement.

March 23, 2024 by Mark Handley

Belgium – multiple raids related to Russian diamonds

On Friday the Antwerp Public Prosecutor’s office announced that it conducted six raids and arrested four individuals in relation to suspected breaches of the EU’s trade sanctions relating to Russian diamonds.

It is being reported that the investigation arose after the seizure of a cargo of diamonds on February, and that a total of three shipments had been seized with a reported value of over €8 million.

December 5, 2023January 11, 2024 by Mark Handley

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.

October 12, 2023January 11, 2024 by Mark Handley

Belgium – raids seize $1.5m in diamonds

The Antwerp Public Prosecutor’s Office has conducted three raids and seized $1.5m in diamonds suspected to have been the result of circumvention of the EU’s Russian sanctions.

A criminal investigation has been launched and a court-appointed expert been put in place.

February 24, 2023January 11, 2024 by Mark Handley

Belgium – 19 reports referred for criminal prosecution

The Belgian Minister of Finance has issued a statement regarding Belgian efforts to enforce the EU’s sanctions against Russia.

Included, is confirmation that 19 reports have been referred to the public prosecutor’s office, and that a further 15 such other such reports are being prepared.

No further information on the nature of the alleged offending was included.

February 7, 2019January 11, 2024 by Mark Handley

Belgium – convictions for breaching Syrian sanctions

It was reported today that the Penal Court of Antwerp has convicted three Belgian companies and associated individuals of breaching the EU’s Syrian sanctions by exporting 168 tons of isopropranol which is a dual-use product.

AAE Chemie Trading was conditionally fined €346,443 with €50,000 effective. Anex Customs was fined €500,000 of which €100,000 is effective and Danmar Logistics were fined between €75,000 of which €50,000 is effective

Rolf Rippen, the manager of AAE Chemie Trading was sentenced to four months in jail suspended, while Herman Van Landeghem, a manager of Anex Customs and Danmar Logistics, received a 12-month custodial sentence.

November 14, 2017January 10, 2024 by Mark Handley

Belgium – raids on premises of holding company of Lafarge-Holcim

It was reported today that the Belgian authorities have conducted raids on the Belgian offices of GBL, a company holding a 9.4% stake in Lafarge-Holcim as part of a wider investigation into allegations that funds were made available to designated persons in breach of EU sanctions.