Germany – 5 year sentence for and confiscation of c. €5m for sanctioned cars exports to Russia

As first reported in Global Sanctions, and as per a press release by German Customs, the Marburg Regional Court on 8 July has sentenced an individual to 5 years in jail for exporting luxury cars to Russian breach of the EU’s sanctions.

The man was convicted of 71 separate counts.

The court also confiscated approximately €5m as the gross proceeds of the cars sales.

Netherlands – two sanctions judgments: i) individual given 3 years prison sentence; and ii) confiscation of €1m in unlawful profits

The Dutch courts have published two sanctions judgments.

In the first case, the District court of Rotterdam has sentenced an individual to three years in jail.

The individual was convicted for providing technical assistance to a person in Russia or for use in Russia of different computer files containing information on the manufacture of microchips. The files were shares by Google Drive and Telegram between January 2023 and August 2024.

The defendant was acquitted of charges of physically taking similar files to Russia on USB sticks.

On sentencing the judgment stated:

Providing advice to and sharing technology with Russia is extremely serious. It can contribute to strengthening military or strategic capabilities of that country, which has an impact on Ukraine and can indirectly affect international security and stability. It is therefore a serious offence. … The nature and seriousness of the facts justify a prison sentence of considerable duration. The fact that the files would contain outdated information is irrelevant because this information can be of great value to a country with a (much) lower level of knowledge. It must be prevented that a country at war can benefit in any way from advanced technological knowledge. After all, for that reason, an extensive package of sanctions has also been agreed against Russia, among others“.

In the second case, the District Court of Amsterdam has issued an order confiscating €1,013,956.00.

The unnamed corporate defendant had been provided goods and services in relation to the construction of the Kirch Bridge, and had been convicted on 28 November 2024 (our previous post here), with a fine of €120,000 imposed.

The court calculated that the gross revenue obtained in breach of sanctions was €2,711,085, but allowed certain costs including internal time incurred and the cost of insurance resulting in a final confiscation of €1,013,956.

The effect of this is that revenue of nearly €1.7m obtained in breach of the EU’s sanctions was retained by the convicted company.

Malta – fines and prosecutions for sanctions violations

As previously posted Malta’s Sanctions Monitoring Board maintains a page or listing companies that have been subjected to a fine of greater than €800 for sanctions breaches.

The page has now been updated to include the fact of a fine against:

  • Felicitas Trust Limited based on a “supervisory examination conducted between April and May 2023”; and
  • Winzon Group Ltd based on a “supervisory examination conducted between February and March 2024”.

No other information is provided, including which sanctions regime was involved.

Separately, the SMB has issued an update on Malta’s implementation of the EU’s Russian sanctions. This notes the completion of 211 inspections, and notes that some of its investigations “are cases advancing through judicial channels”.

No further information is provided on these, presumed, prosecutions.

    United Kingdom – £1.1m penalty for exports to Russia

    HM Revenue and Customs has issued a Notice to Exporters reporting on the imposition of a civil compound penalty against an unnamed company for making “goods available to Russia in breach of” the UK’s Russian sanctions.

    The penalty is stated to be £1,160,725.67.

    No other information has been published on the identity of the offender, the nature of the offending or the goods that were exported, whether there was a self-report, or the nature of the cooperation that secured a civil penalty.

    Latvia – 91 proceedings to confiscate the “proceeds of crime” arising from EU sanctions breaches

    Latvia’s Customs has issued a press release providing details on a recent confiscation proceeding, and providing some data on confiscation proceedings over all.

    The press release states that 91 proceedings have been commenced to confiscate criminal property arising from breaches of EU sanctions.

    It is noted that to date 57 of these proceedings have resulted in the confiscation of assets totalling €1,935,683.

    The particular recent case outlined in the press release relates to the confiscation of a truck and trailer that had been stopped and searched at the Terekhova customs point. Officers suspected that the truck was itself being exported, and an investigation was commenced.

    By court decision of 9 June 2025 the truck and its trailer, valued at €52,500, were confiscated.

    France – financial services regulator fines bank €600,000 for sanctions compliance failings

    France’s ACPR has issued a press release making public a fine of €600,000 imposed on Banque Delubac.

    The detailed Décision, make clear that the compliance failings predominantly relate to AML and CTF failings, but Complaint 9 relates to sanctions compliance. The ACPR noted a failure by the bank to collect data on directors and beneficial owners for more than a quarter of its business customers. Further, the bank applied no screening at all on transactions valued at below €1,000 between 2020 and 2022/203.

    The size of the fine is said to reflect the €3m spent on improving the bank’s compliance, and the bank’s loss for the financial year 2024.

    United Kingdom – law firm fined £600 for breach of Russian sanctions licence conditions

    The Solicitors Regulation Authority (the “SRA”) has fined Steptoe International LLP £600 and given the firm a “rebuke” for breaches of the UK’s Russian sanctions.

    The breaches are reported to have related to two clients, and involved non-compliance with the conditions of relevant licences granted by OFSI, which is a criminal offence. It is unclear whether this was a general licence or a specific licence.

    The firm self-reported the breaches to the SRA, which accepted that the breaches were the result of “inadvertent human error”.

    The report makes no mention of any involvement by OFSI.

    United Kingdom – OFSI imposes £5,000 fine for refusing to respond to information request

    The UK’s OFSI has announced a £5,000 monetary penalty imposed on Svarog Shipping & Trading Company Limited.

    The fine was for failing to respond to an information request from OFSI in breach of regulation 74(1)(a) of the UK’s Russian sanctions regulation.

    The Penalty Notice states that the request for information was made in the context of a wider “large and complex investigation into suspected breaches” of the UK’s sanctions in relation to Sovcomflot. That investigation is, presumably, ongoing.

    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.

    Estonia – details of eleven Russian sanctions convictions

    Further to the earlier post about Estonia having obtained 8 criminal convictions during 2024, we can publish details of the criminal convictions for breaches of the EU’s Russian sanctions that have been published on Estonia’s searchable gazette of published judgments.

    As well as one conviction obtained in 2022, below we are publishing summaries of seven of the convictions from 2024 and three from 2025 (not including the conviction made public on 16 April 2025) as well as machine translations of the respective judgments.

    The sentences range from fairly small monetary fines up to custodial sentences of 5 years in jail.

    1. Judgment of 10 October 2022 – Petr Rafalovich (a Belarus national) was convicted and given a two month sentence following which he was to be deported to Belarus and given a five-year ban from re-entering Estonia. He was also ordered to pay a penalty and costs of €1,250.40.

    The offence was the attempt to export a 3D printer and an electromagnetic positioner. Mr Rafalovich was carrying false papers indicating the goods were destined for an Armenian company, as well as other papers indicating the true recipient to be a Russian company.

    2. Judgment of 5 February 2024 – Victor Manilo was convicted and ordered to pay €2,680 as a fine.

    The offence was the attempted export of €14,000 in physical currency to Russia.

    3. Judgment of 14 February 2024 – Galina Sergejenkova was convicted and ordered to pay €3,960, such payment suspended for a probationary period of 18 months. A separate payment of costs and a penalty of €1,434.96 were to be paid straightaway.

    The offences were two attempts to transport physical currency (of €900 and €1,000 respectively).

    4. Judgment of 27 February 2024 – Evgeniy Kozlovtsev was convicted and given an eight month sentence suspended for a probationary period of 18 months. He was also ordered to pay a penalty and costs of €1,430.

    The offence was the attempted export to Russia of two bottles of wine greater than the €300 luxury threshold. It was the man’s second attempt at such exports.

    5. Judgment of 8 March 2024 – Aleksei Bond was convicted and given a five month prison sentence suspended for a probationary period of 18 months. He was also ordered to pay a penalty and costs of €1,555.

    The offence was the attempted export of a luxury watch valued at €13,900 to Russia.

    6. Judgment of 27 March 2024 – Lev Pylkin was convicted and ordered to pay a penalty of €1,190, as well as confiscation of the cash he attempted to export to Russia.

    The offence was the attempted export of €2,560 in physical currency across the border to Russia. He had previously attempted to export cash at which time the details of the offence had been explained. The judgment is the dismissal of an appeal against the conviction and sentence.

    7. Judgment of 17 October 2024 – Ruslan Sibilev was convicted and ordered to pay a fine of €79,557.50 as well as confiscation of a large number of rifle scopes, binoculars and other equipment.

    The offences were committed through the acquisition of a range of sanctioned goods from a Portuguese company and an Austrian company, with Sibilev acting to coordinate further transport for the export of the goods to Russia. The orders were placed between May 2022 and April 2023. The total value of the goods ordered was nearly €1 million.

    8. Judgment of 16 December 2024 – Oleg Osipov was convicted and sentenced to 8 months in prison suspended for a probationary period of 18 months. He was also ordered to pay €13,230, including 100% of the fee earned as part of the sanctioned transactions.

    The offences were committed through Osipov providing a brokering service for the export of luxury goods to buyers in Russia between May and July 2023. The goods included electrical goods, phones, alcohol, navigation systems and various automotive parts. Osipov contracted with others to deliver the goods and took a brokering fee for arranging the transactions.

    9. Judgment of 14 February 2025 – Demyan Belyakov was convicted and sentenced to 5 years in jail and ordered to pay €8,231 in costs and other penalties. In addition a large volume of goods were confiscated.

    The offences were committed through the actual and attempted export to Russia of hundreds of silencers and firearm flash suppressors between February and June 2024.

    10. Judgment of 20 February 2025 – Andrei Klychkov was convicted and sentenced to serve two months in prison plus a further period of 2 years and 10 months suspended for a probationary period of 4 years. €5,000 was also confiscated and he was ordered to pay costs of €2,581.

    The offences were committed by the attempted export of parts for firearms, to Russia.

    11. Judgment of 21 March 2025 – Aleksandr Ivantsov was convicted and sentenced to 4 years, 11 months and 27 days (after deducting 3 days of pre-trial detention) suspended for a probationary period of 5 years and other conditions including a requirement for prior permission to be away from his house for more than 15 days, and permission to leave Estonia. He was also ordered to pay €2,215 and had 70,550 rubles, and other goods, confiscated.

    The offence was committed by the attempted export of six pairs of night-vision binoculars.

    This case is related to that above for Ruslan Sibilev with Mr Ivantsov being one of the people used to try and physically carry the goods across the border into Russia.

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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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