It is being reported that Latvia’s State Security Service has referred four individuals for prosecution for alleged exports of satellite communications equipment for the Russian military in breach of EU sanctions and other Latvian laws.
The investigation is ongoing and it is reported that other individuals are suspected of being involved.
The goods exported were Starlink Mini satellite communication systems.
The UK’s HM Revenue and Customs has published a compound penalty of £374,326.07 against an unnamed UK company for “unlicensed exports of dual-use goods and failure to declare a licence to customs”.
No further details were provided as to the nature of the conduct or the basis for offering a compound penalty rather than a prosecution.
In a letter written from the UK’s HMRC (the body with primary responsibility for the criminal enforcement of trade sanctions) to Parliament’s Treasury Select Committee, HMRC has provided significant information on its recent enforcement efforts.
| Year | Number of investigations opened |
| 2021 | 0 |
| 2022 | 14 (all relating to Russian sanctions) |
| 2023 | 22 (20 relating to Russian sanctions) |
| 2024 | 29 (27 relating to Russian sanctions) |
Of those 65 investigations, HMRC has confirmed that 30 remain live of which 27 relate to Russian sanctions.
The letter tabulates the six fines imposed to date for breaches of the Russian sanctions, and in relation to the largest single fine of £1,000,000 imposed in August 2023 (see our earlier post), the letter notes that this fine relates to “brokering and technical assistance” and not to an actual export.
HMRC’s letter also states that a previously published compound penalty of £1,000 from September 2023 (see our earlier post) was actually for a breach of the UK’s Iran sanctions despite being described at the time as “relating to the attempted export of Dual Use goods”.
HMRC’s letter also states that in October 2024 it referred a case for possible prosecution to the Crown Prosecution Service.
The Spanish authorities have issued a press release confirming a series of raids in the provinces of Barcelona and Valencia and the arrest of five people.
The raids and arrests are said to be the second phase of Operation Probirka, the first phase of which was conducted in October 2024 (see our previous post).
The bodies involved were the National Police and the Tax Agency.
The allegations include the use of front companies and dummy intermediaries in Kyrgyzstan and Armenia, and the export of chemicals which can be used in the manufacture of explosives and chemical weapons.
On 4 November 2024, HMRC published a Notice to Exporters regarding a compound penalty of £58,426.45 imposed for breaches of Russian trade sanctions.
The Notice included the line:
“Since February 2022, HMRC has issued six compound settlements against UK companies that have breached the Russia sanctions regulations for a total of £1,363,129, including one in August 2023 for £1 million“.
This struck a chord because, as captured in this blog, only three compound penalties had been publicly imposed by HMRC for breaching Russian sanctions. So a Freedom of Information request was made about the other three.
The response is here.
The response discloses details of three compound penalties (totalling c. £237,000) from August and September 2022 and April 2023. These had each been previously published, but had not previously been described as relating to Russian sanctions.
It is unclear why these penalties were not previously described as relating to breaches of Russian sanctions.
The FOIA request also asked for the names of the individuals or companies which were the subject of the penalties; whether any had self-reported; and what (if any) confiscation of the proceeds of crime was applied. These questions were not answered.
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.
It is being reported that Polish authorities have arrested and charged a German national with exporting dual-use technology to Russia in breach of EU sanctions.
The arrest was in the Lubusz province and relates to the export of machinery which can be used in weapons manufacture. It is also said that the exports were directed at “Russian military plants involved in weapons production”.
The individual is reported to have admitted his guilt.
The Rotterdam District Court has issued two judgments relating to the conviction and sentencing of an individual for exporting computer goods and software destined for Russian companies via intermediaries in Kazakhstan, Kyrgyzstan and Uzbekistan.
According to the judgment convicting the individual, the man had been selling computer equipment to two Russian companies prior to 2022. After the goods in questions became sanctioned, a fact he was made aware of by his customs agent, the man directed the exports to affiliates of his Russian customers in Kazakhstan, Kyrgyzstan and Uzbekistan. All the communications, however, remained with the Russian companies.
In an attempt to cover his tracks the man forged a contract between his company and the central Asian entities and provided this in response to questions from his bank.
The court convicted him of the charges, including forgery, holding that the EU Regulations did not require proof that the goods were actually delivered to Russia.
The exports in question were of thousands of items which were either dual-use or luxury goods and were predominantly computer equipment and software.
At sentencing the court made a number of comments:
The man was given a custodial sentence equivalent to the length of his time served in pre-trial detention (450 days), a suspended sentence of just over 11 months, suspended for two years, and a community service order of 240 hours.
Goods which had been seized during the investigation were returned to him.
The second judgment related to confiscation of the proceeds of crime from the man.
The court calculated that the gross proceeds of the crimes were €1,924,579, from which the court deducted €1,626,269 in what it described as “deductible costs”, leaving a final figure for confiscation of €298,310 which the court considered to be the company’s “profit”. This was the amount the man was ordered to pay by way of confiscation order.
The judgment does not record the Court (or the prosecution) giving consideration to the recent CJEU judgment which upheld a confiscation of the gross proceeds of crime.
It is being reported that the Higher Regional Court in Stuttgart has convicted Ulli S, a 56 year old man, of breaches of the EU sanctions against Russia and the German foreign trade law.
As per our earlier posts, the man was arrested in August 2023, and had been charged in November 2023.
The exports were of machinery which can be used for the manufacture of sniper rifles and other weapons. Some of the exports were sent to Russia via Switzerland and others via Lithuania, while the customs data was falsified.
The contracts for the supply of the goods had been entered into in 2015.
The individual is said to have profited by 2.1 million euros, while a Swiss holding company benefitted by roughly 3 million euros. According to Der Spiegel these sums have been confiscated.
The trial lasted several months and is subject to a possible appeal.
The UK’s HMRC has issued several “Notices to Exporters” with updates as to recent enforcement activity.
In one Notice, HMRC states that is has agreed three compound penalties with different entities:
As ever with such penalties the nature of the offending is not given, the identity of the offender is not given, and no indication is given as to whether or not the fine includes a confiscation element for the proceeds of the crimes.
In a second Notice, HMRC describes the compound penalty:
“August 2024 – £58,426.45 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019”.
Again, no other details or information is provided, although HMRC notes that this is its 6th compound penalty in relation to Russian sanctions totaling £1,363,129.
