The German authorities have published the third instalment of their 6-monthly updates on their current enforcement actions.
The report highlights:
- The conviction on 2 March 2026 of two individuals relating to the export of 111 luxury cars to Russia, with €20m confiscated, and jail sentences of 6 years and 2 years (the latter suspended). See our previous post.
- Raids conducted in November 2025 and the ongoing investigation into the suspected export of machine tool to Russia value at €1.7m. The report confirms that the investigation by the Stuttgart Public Prosecutor’s Office and the Stuttgart Customs Investigation Office remains ongoing. See our previous post.
- An investigation into five suspects for the organized circumvention of sanctions against Russia. A company is alleged to have exported technical equipment and accessories worth c. €689,000 to a company in Russia via third countries. The investigation started in February 2025 and is being conducted by the Essen customs investigation office, is ongoing. See our previous post.
- The prosecution of a 41-year old suspected of exporting 236 cars to Russia valued at approximately €18.86m. See our previous post.
- The arrest of five suspects on 2 February suspected of 16,000 illegal deliveries to 24 listed Russian arms companies of good worth at least €30m. The prosecution was supported by the Federal Intelligence Service (the BND). See our previous post.
- On 27 March raids conducted on 14 premises in the Rhine-Main region against two companies suspected of exporting machine parts and chemicals to Russia. A third company is said to have been involved in the alleged use of a transport and logistics companies to try and circumvent the EU’s sanctions. See our previous post.
- The ongoing investigation into a member of the Saxon state parliament for allegedly falsifying the export declaration in relation to a telescopic handler rather than stating the correct destination of Belarus. Searches were conducted at residential and business premises. See our earlier post.
The update also reports on a decision of the CJEU from 5 February 2026 upholding the seizure by German customs of a Mercedes car purchased in Russia and imported to Germany. The CJEU held that the single specific import did not need to “generate significant revenue for the Russian state”, so long as the general category of goods did.
Further cases noted previously in the blog over the last few months, but not included in the report are:
- an investigation from February 2026 in relation to the import of goods valued at over €4m from Russia;
- an investigation made public in January 2026 into the use of RussPost to export goods to Russia;
- reporting from January 2026 into a mutual legal assistance request made to Ukraine as part of an investigation into the suspected export of drone parts to Russia;
- the arrest in January 2026 of two people on suspicion of making available funds and economic resources to the Donetsk and Luhansk People’s Republics;
- an investigation made public in December 2025 by the Munich Prosecutor’s Office into alleged export of 50 luxury cars valued at over €10m; and
- raids in November 2025 in relation to the suspected export of 346 cars to Russia.