Dual-Use Goods – Page 2 – European Sanctions Enforcement

July 18, 2024July 22, 2024 by Mark Handley

Germany – two individuals convicted of electronics exports to Russia

A court in Stuttgart has convicted two individuals for their role in the export of 120,000 dual-use items to Russia between January 2020 and May 2023. The parts included those used for the “Orlan 10” drone. The value of the goods was estimated at €875,000. Another report states that this amount was confiscated as part of the sentencing.

One individual was given a custodial sentence of 6 years and 9 months and the other was given a suspended sentence of 1 year and 9 months.

The scheme had involved disguised sales and invoices involving Hong Kong and Turkey, as well as false documents indicating that some of the goods had been sold to customers in Germany.

As per our earlier post, the individuals were charged had been charged in March 2024.

May 31, 2024 by Mark Handley

Lithuania – four suspects being investigated for dual-use exports

Further to our earlier post, it is being reported that the Lithuanian Prosecutor General is now investigating four separate suspects in relation to the alleged export of dual-use goods to Russia by the Vičiūnai Group.

The alleged recipient of the goods, which includes high-priority battlefield items, was a Russian subsidiary within the Vičiūnai Group.

May 16, 2024May 16, 2024 by Mark Handley

United Kingdom – HMRC corrects/changes description of earlier fine to withdraw reference to Russian sanctions

Back in April we posted about a Compound Penalty imposed by HMRC on a company for breaching the UK’s Russian Sanctions Regulations.

The company was fined £1,058,781.79.

HMRC has today issued a changed Notice to Exporters about this fine. The changed description removes any reference to the UK’s Russian sanctions regulations and replaces it with:

“March 2024 – £1,058,781.79 was paid relating to the unlicensed exports of dual use goods controlled by Retained Regulation 428/2009“.

No explanation for the change is given.

May 6, 2024 by Mark Handley

Finland – three individuals arrested on suspicion of dual-use exports to Russia

It is being reported that on Friday three Russian nationals, aged 25, 25 and 18, were arrested in Finland on suspicion of the export of dual-use goods to Russia in breach of the EU’s sanctions.

The goods are reported to be electronic components such as sensors and lasers.

May 6, 2024 by Mark Handley

Germany – trial starts of three individuals accused of drone exports to Russia

Further to our earlier post about the laying of charges against three individuals accused of exporting drones and drone parts to Russia in breach of the EU’s sanctions, the criminal trial of these individuals started on Friday.

The three are, between them, accused of 54 counts of breaching sanctions.

The conduct is alleged to have included exports to front companies in Kazakhstan, Kyrgyzstan, Hong Kong, Turkey and the United Arab Emirates, and of deceiving component suppliers based in the US by saying that Germany was to be the final destination of the products.

April 25, 2024May 16, 2024 by Mark Handley

United Kingdom – HMRC issues £2.3m in compound penalties for sanctions and export controls breaches

His Majesty’s Revenue and Customs, the body empowered to enforce export controls and trade sanctions in the UK, has today published two Notices to Exporters setting out compound penalties in relation to Russian sanctions and export control violations.

The first Notice, in relation to an unnamed company, relates to a penalty of £1,058,781.79 imposed for breaches of the UK’s Russian sanctions regulation.

No information is given as to the nature of the conduct, the value of the goods, or why a criminal prosecution was not brought. There is no mention of a confiscation of the proceeds of crime.

The second Notice relates to export control violations that are not described as breaches of the UK’s sanction. Again no information is given as to the names of the companies, the nature of the violations, or an indication given as to the confiscation of the proceeds of crime.

To quote the Notice:

“The 6 settlements made by UK companies were:

- January 2024 – £12,700.00 was paid for a breach of licence conditions in relation to the export of military goods
- February 2024 – £33,822.64 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008
- February 2024 – £971,726.00 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008
- February 2024 – £139,841.85 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008 and dual use goods controlled by Retained Regulation 428/2009
- March 2024 – £92,817.40 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008
- March 2024 – £56,915.27 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008“.

April 22, 2024April 22, 2024 by Mark Handley

Germany – charges laid in relation to exports to China

The German Federal Prosecutor’s office issued a press release earlier today in relation to the charging of three individuals for alleged export control violations.

The three charged are German nationals named as Herwig F., Ina F. and Thomas R.

It is alleged that the three were working for or on behalf of a Chinese intelligence agency and that they worked to procure information in relation to technology with military application, including ship engines.

The defendants are also charged with the unlicensed export of a laser to china in breach of the EU’s Dual-Use Regulation.

April 10, 2024 by Mark Handley

Lithuania – Customs Department launches investigation into exports to Russia

Following press reporting into allegations that the Viciūnai Group of companies were exporting sanctioned goods to Russia, it is now being reported that the Lithuanian Customs Department has commenced a pre-trial investigation.

The allegations include that dual use and “battlefield” goods were being exported to a factory in Kaliningrad operated by a related company.

It is reported that the company has confirmed the fact of the exports, but claims that it was not aware that the goods in question (which includes ball bearings, semi-conductors, electrical components and other goods) were subject to sanctions.

March 15, 2024March 15, 2024 by Mark Handley

European sanctions enforcement: the last two months

This blog has been live now for just over two months.

During that time and by way of recap, a number of states have provided updated enforcement statistics in that period (Finland, Switzerland, Latvia), but the period has also seen a significant volume of new enforcement activity:

Continue reading “European sanctions enforcement: the last two months”

March 6, 2024 by Mark Handley

Germany – two charged for exporting drone components in breach of Russian sanctions

The Federal Prosecutor’s Office in Germany has charged two individuals (named as Waldemar W. and Natalie S.) with the export of electronic drone components to Russian in breach of EU sanctions.

The components were first imported into Germany and then exported via Kyrgyzstan and Hong-Kong. The charges relates to 54 separate shipments up to March 2023. The shipments date from both before and since the large-scale invasion of Ukraine.

The total value of the components is stated as €875,000.

Waldemar W was the managing director of two involved companies incorporated in Saarland wand Natalie S managed a company in Baden-Württemberg. It is alleged that suppliers were provided with false end-user information which purported to confirm that the goods were to remain in Germany.

Waldemar W. has been in custody since 9 March 2023. Natalie S. was in custody previously but was subsequently released.