It is being reported that the Estonian authorities have arrested and detained a 65-year old named only as Tatjana, for allegedly managing and handling funds on behalf of the Foundation for the Support and Protection of the Rights of Russian Compatriots Living Abroad, which is a designated person under the EU’s sanctions.
It is alleged that Tatjana received €50,000 from the Foundation and used the money to fund a person’s defence in an ongoing criminal trial in Estonia.
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 the Czech authorities have an unspecified number of ongoing investigations into Czech companies suspected of circumventing the EU’s Russian sanctions.
As per our earlier post from June 2023, it was then reported that Czechia had 40 ongoing investigations.
It is being reported that the Kurzeme District Court has sentenced the Latvian citizen Valentins Rozencovs, to 2 years in jail.
The sentence was that sought by the prosecution, although the case is subject to appeal.
Rozencovs was the editor-in-chief of Sputnik Latvija which is the Latvian branch of Sputnik which operates under the umbrella of a Russian state-owned media company Rossiya Segodnya.
The Director General of Rossiya Segodnya is a designated person (Dmitry Kiselyov), and the prosecution was based on the premise that the provision of services by Valentins Rozencovs was making economic resources available to a designated person, and that Sputnik Latvija was “owned or controlled” by Kiselyov.
This is the latest in a series of prosecutions relating to Rossiya Segodnya – see our earlier posts, here and here.
An article in Latvia’s LTV has provided an update on a number of features of Latvian sanctions enforcement.
Firstly, the Customs Administration stated that they had confirmed 2,623 breaches of sanctions so far this year up from 2,175 in 2023.
It was also stated that to date “€662,498.27 worth of goods have been confiscated in favor of the State in criminal proceedings for breach of sanctions”.
This is a substantially higher figure that those for confiscations identified in our recent post summarising Latvian convictions obtained in 2022 and 2023.
The article also stated that a total of 14 prosecutions had been brought in relation to the making available of economic resources to companies (i.e. the websites Sputnik and Baltnews) owned or controlled by Dmitry Kiselyov.
Two of those prosecutions ended in convictions in 2023 (as per our earlier post above), but the article adds that “This year [i.e. 2024], three more cases have ended in fines and community service”.
Lastly, the article adds that there have been two other convictions obtained during 2024, but that none of the 2024 judgments have yet entered into force.
Although not mentioned in the article, it has been confirmed to me by Paulis Iljenkovs of Latvia’s FIU (who has also consented to me sharing the information), that Latvia currently has 382 ongoing sanctions investigations.
As an addition to the existing prosecution it is being reported that the National Crime Agency has added two new charges to those against Alexei Owsjanikow. It is alleged that he paid £41,027.25 on behalf of his brother-in-law, designated person Dmitrii Ovsiannikov, towards private school fees.
The payments are said to have been made in May this year, which would be after Owsjanikow had already been charged with other sanctions offences.
The trial for this prosecution is currently scheduled for March 2025.
With gratitude to a Paulis Iljenkovs of the Latvian FIU who pointed me to the website of Latvian anonymised case law, we can publish details of the criminal convictions to date under the EU’s Russian and Belarusian sanctions regimes.
As per an earlier post (here) it had been reported that there had been seven convictions to over 2022 and 2023. When including cases where companies and individuals were both convicted the correct figure is 10 convictions in 7 cases.
The website including Latvia case law is here. The case numbers provided below can be entered into the “Atlasīt pēc arhīva numura:” window to retrieve the judgments themselves which are in Latvian.
A. Case K77-3109-23. Riga City Court. 30 October 2023.
This case concerned the export of a Bentley Mulsanne Speed luxury vehicle to Russia that was sold for €112,552.69 in breach of the EU’s prohibitions on the export of luxury goods.
The company was convicted and fined €111,600 and had the full proceeds from the sale of the car confiscated as well.
The senior individual within the company was also convicted and personally fined €62,000.
In an earlier post we had reported that the total fine from this case was €170,000, but this sum excluded the confiscation.
B. Case K77-2464-23. Riga City Court. 25 October 2023.
The case was the prosecution of an individual who worked for Rossiya Segodnya, a Russian state media channel (the company is not named in the judgment, but is known from earlier press releases as per our earlier post).
The journalist was prosecuted for making “economic resources” available to a designated person, with Rossiya Segodnya having a designated person – Dmitry Kiselev – as its Director General.
The court held that the work product prepared during the course of employment constituted “economic resources” and that making these available to a designated person was a breach of the asset freeze imposed on Kiselev under the EU’s sanctions.
The fine was €6,820.
C. Case K77-2465-23. Riga City Court. 26 June 2023.
This case is twinned with Case B (K77-2464-23) above. The prosecution was of another journalist working for the same organisation, and the same case theory of the work product constituting “economic resources” was pursued.
In this instance, however, the journalist pleaded guilty and expressed remorse.
As part of a plea deal the individual was sentenced to 140 hours of community service.
The judgment itself concerned whether this plea deal was procedurally proper as a matter of Latvia law, and it was upheld.
D. Case K77-3055-23. Riga City Court. 17 October 2023.
This case was the prosecution of a company and individual for importing gas cylinders and valves from Belarus in breach of import prohibitions under the EU’s sanctions. The contract value was €73,508.
A senior person within the company, and the company itself were prosecuted and convicted.
The individual was fined €12,400.
The company was fined double that sum – €24,800, and had profits of €9,500 confiscated. This figure is not explained but may have been the profit made from on-selling the imported goods. The company was also banned from conducting any further business with Belarus for a year.
E. Case K12-0283-23. Daugavpils Court. 14 April 2023.
We have posted on this conviction previously.
The case concerned the conviction of an individual for importing 8kg of nails and 13 consignments of railway sleepers from Belarus in breach of the EU’s sanctions.
The man was fined €6,200 and barred from importing any goods from Belarus for a year.
A co-accused was also convicted (the judgment for which could not be found on the case law website) and was fined €5,000 and given a similar ban from importing any goods from Belarus for a year.
F. Case K77-1597-23. Riga City Court. 20 February 2023.
This case concerned the transfer of a professional football player from a Latvian club to a Belarussian club that was 79% owned by a designated person.
The transfer fee was US$50,000.
The player was treated in the judgment as an “economic resource” made available to a designated person in breach of the EU’s asset freeze.
The senior individual at the Latvian club pleaded guilty and was fined €6,200.
The club was also convicted and had the full US$50,000 transfer fee confiscated.
The news website g4media in Romania has made a Freedom of Information request to Romania’s ANAF enforcement agency.
It has published an article summarising the results, and also provided the original response.
The response identifies the following enforcement statistics:
As per our earlier post, as of November 2022, Romania was reported to have imposed fines of 280,000 lei and confiscated 13,171,000 lei (c. €2,650,000). The balance of these further fines have been imposed since that date.
Global Investigations Review (behind a paywall) has published the results of a Freedom of Information request to the Crown Prosecution Service which reveals that the CPS has been asked to advise on a total of three cases under Russian sanctions, two of which are not otherwise in the public domain.
One of the newly-revealed relates to financial sanctions, and the other to trade sanctions.
The third is case relates to the ongoing prosecution of three individuals.
The CPS has not yet added this Freedom of Information response to its website.
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:
2018:
2019:
2020:
2021:
2022:
2023:
2024:
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.
