Finland – sanctions enforcement statistics: over 900 investigations, hundreds of fines and dozens of convictions

Press reporting in Finland has provided an update on Finland’s sanctions enforcement.

The update provides:

  • over 900 preliminary investigations commenced by Finnish Customs:
    • 13 started between 2018 and 2021;
    • 306 started in 2022;
    • 492 started in 2023; and
    • 83 started in 2024 (January to September, with an uncertain number since then)
  • “More than half” involved minor regulatory offences and have been resolved by monetary fines without recourse to the court system. These cases are further described as: “The fine cases mainly concern private individuals who have exported small quantities of banned goods across the border. Private individuals have exported, for example, luxury goods, not equipment needed by the military“.
  • “Dozens” of convictions and fines imposed by the courts for more serious offences. These are described as: “characterized by planning, systematicity and the pursuit of significant financial gain. Most often, they involve equipment needed on the front line. … The perpetrators in such cases are typically small or medium-sized export or logistics companies“.

The report provides no further details on the precise number of fines, the amount of fines, or other sentencing involved.

A separate report notes that the Finnish Navy has established a controlled area in the Gulf of Finland where Russian-linked vessels are inspected. This de facto maritime detention zone is encircled by Finnish naval forces and that currently 20 Russian “shadow fleet” vessels are “under scrutiny, with several facing potential long-term detention“.

Finland – sanctions investigation closed into returned Russian art

In April 2022 Finnish Customs seized over 200 pieces of art being shipped back to Russian museums such as the State Hermitage Museum and the Tretyakov Gallery.

It is now being reported that at that time an investigation was commenced by Finnish Customs working with the Finnish Foreign Ministry as to whether permitting the onward transit of the objects and artefacts, or the shipments themselves, would amount to breaching EU sanctions.

The artefacts were later allowed to travel on to Russia while the investigation continued.

As of 24 December 2024, it is now being reported (in the linked article above) that the investigation has concluded with no further action to be taken.

Bermuda – trust company fined $600,000 for sanctions and AML compliance failings

On 30 December the Bermuda Monetary Authority announced the imposition of a fine of $600,000 on Meritus Trust Company Limited for a series of AML and sanctions compliance failings.

In terms of sanctions compliance the failing was specified as “An overreliance on manual processes to implement international sanctions policies and procedures and sanctions screening“.

The BMA’s on-site investigation was commenced in June 2022 and the company was then given a deadline of July 2023 to complete the necessary remediation. The BMA was satisfied with the company’s efforts and noted a number of mitigating factors such as a low risk of loss to clients, co-operation, the remediation efforts, and the company’s overall culture of compliance.

This is a rare example of a sanctions enforcement fine being imposed in one of the UK’s overseas territories or crown dependencies. The only other example known (to this blog) are the fines and other punishments imposed in Guernsey in 2015/2016.

Estonia – person detained for alleged breach of designated person’s asset freeze

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.

Denmark – sanctions enforcement activity 2022-2024

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.

Latvia – 2-year jail sentence for breaching designated person’s asset freeze

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.

Latvia – update on current sanctions enforcement including 5 convictions in 2024

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.

United Kingdom – further charges against individual already facing prosecution for breaching Russian sanctions

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.

Latvia – details of the 10 Russian/Belarusian sanctions convictions from 2022 and 2023

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.

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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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