Germany – conviction and lengthy jail term for sanctioned exports to Russia

Further to our earlier post, it is being reported (here, here and here) that in September a court in Frankfurt convicted Alexander S. of exports of sanctioned goods to Russia.

He is reported to have been sentenced to 4 years and 11 months in jail. Both the defence and prosecution have appealed.

The conviction relates to exports of dual use maritime technology to Russia via a procurement network said to be run through the Cypriot company Mostrello.

Finland – suspended sentence on conviction for dual-use exports to Russia

It is being reported, that after pleading guilty to charges of exporting dual-use goods to Russian in breach of the EU’s sanctions, a 20-year old student has been given a 14-month suspended sentence.

The student exported dual-use drones, laptops, computer processors, smartphones and laser rangefinders valued at nearly €74,000.

Further to our earlier post, two other accomplices were also arrested in May 2024 and have been investigated for exports valued at another €70,000.

As well as pleading guilty the student is said to have co-operated with the investigation. The outcome relating to the other two defendants is not yet known.

Switzerland – investigation into alleged spyware exports

As reported by GIR (behind a paywall) a decision by the Swiss Supreme Court has revealed an ongoing investigation by the Swiss Office of the Attorney General into alleged exports of spyware software to various countries in breach of Swiss export control laws.

The investigation relates to Andrea Gambazzi, and the company Thalestris Switzerland.

The judgment itself relates to whether documents seized as part of a raid by the authorities can, or cannot, be used as part of the investigation.

The investigation is reported to have been commenced in June 2024.

Finland – investigation commenced into Helsinki logistics company for sanctioned exports to Russia

Finland’s Customs has issued a press release announcing the an investigation into a company in the Helsinki region that is suspected or arranging exports of goods to Russia via third countries including Lithuania, Bulgaria, Poland, Belarus, Kazakhstan and Kyrgyzstan.

The exports are suspected of ranging from 2022 to 2025, and to have included direct sales by the company.

The goods involved are ball bearings and industrial motors with an estimated value of €300,000.

The investigation appears to have been started with the interception of a consignment of prohibited dual-use goods which was being directly exported from Finland to Russia.

Czechia – investigations announced into 12 companies suspected of sanctioned exports to Russia

After press reporting by The Insider, into the acitivties of Czech companies allegedly exporting to Russia, it has now been reported that the Czech authorities are undertaking investigations into the companies.

The exports of machinery and duel-use goods (valued at more than €10m) are said to have largely gone through a range of third countries such as Estonia, Serbia, Turkey, and Latvia.

Confirmation of the investigations came from Czech Foreign Minister Jan Lipavský and Minister of Industry and Trade Lukáš Vlček.

The companies under investigation are:

  • Šmeral Brno
  • Varnsdorf
  • TAJMAC-ZPS
  • Pilous-Pásové Pily
  • Jihostroj a.s.
  • N.Ko
  • Prestar
  • Tachtech s.r.o.
  • Stroje Zeman Trade
  • Permico s.r.o.

Spain – arrests and detentions for the export of prohibited machinery to Russia

It is being reported that as part of a joint investigation by the General Information Commissariat, the Customs Surveillance Directorate of the Tax Agency, and the National Intelligence Centre that a raid was conducted in 10 June in the town of San Vicente del Raspeig in Alicante and three individuals have been arrested.

Following a hearing on Friday two of the arrested were imprisoned pending investigations and the third individual has been released.

It is alleged that an unnamed company exported machinery “mainly used in mass production industries, such as the automotive metallurgical industry, the aerospace industry, or also in the military industry“. It is alleged that the exports to Russia were conducted through third countries, that customs data was falsified, and that the end customer was a designated person under the EU’s sanctions.

The machinery is reported to have been valued at hundreds of thousands of euros.

Netherlands – appeal brought to increase 18 month sentence for Russian exports

In an earlier post, we reported on the October 2023 sentence of an individual to 18 months in jail, and a fine of €200,000 imposed on the company operated by the individual.

It is now being reported that an appeal has been brought by the Dutch Public Prosecution Service (the “OM”) seeking to increase the sentence.

The OM are seeking a three-year custodial sentence, a five-year ban from the individual acting as a director, and confiscation of €72,697.71 of the proceeds of the sanctions breaches.

It is reported that the appeal is based on the deliberate nature of the offending with the export of sanctioned goods to Russia via third countries including the Maldives and Kazakhstan.

There is no appeal in relation to the fine of €200,000 imposed on Woerd-Tech BV.

Latvia – prosecutions brought against four for exports to Russia

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.

United Kingdom – HMRC has opened 65 trade sanctions investigations since 2022

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.

YearNumber of investigations opened
20210
202214 (all relating to Russian sanctions)
202322 (20 relating to Russian sanctions)
202429 (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.

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The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

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