Finland – updated statistics on its 909 Russian trade sanctions investigations

As an update to our previous post on the 900 or so sanctions investigations started by Finnish Customs since the start of 2022, we can provide a more detailed breakdown of those figures.

The blog is happy to acknowledge the information and assistance provided by Finnish Customs.

To explain the figures below, under Finnish law sanctions offences are divided into three categories:

  • Petty regulation offences – punishable only by fines;
  • Regulation offences – punishable by fine or imprisonment for a maximum of 2 years; and
  • Aggravated regulation offences – punishable by imprisonment of at least 4 months and not more than 4 years.

Against that background, Finnish Customs has provided a break down over time of when it commenced its many investigations and the category of offending that was being investigated.

YearPetty Regulation OffenceRegulation OffenceAggravated Regulation OffenceTotal
202210415844306
20233548664504
20245593599
Total463303143909

The drop off in investigations relating to petty regulation offences in 2024 is to be attributed to the closure of all crossings along the land border with Russia, as most of the examples in that category had been attempts to export prohibited goods by individuals in cars and other vehicles.

Germany and Finland: sanctions investigations re seized “shadow fleet” vessels

It is being reported that the Panama-flagged vessel, the Eventin which has been seized and detained by Germany after it lost power on 10 January, is currently the subject of a sanctions investigation by the General Customs Inspection Office.

The investigation relates to the cargo of 100,000 tons of oil on board.

In a similar story, it is being reported that the Finnish authorities have concluded an investigation into possible sanctions breaches in relation to the Eagle S, the vessel suspected of being involved in disruption to undersea cables.

The Finnish authorities investigated the cargo of unleaded petrol and diesel on board, but determined that as the vessel only entered Finland’s territorial waters at the request of the Finnish authorities it cannot be said to have intentionally violated the prohibitions on the import of Russian oil products.

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.

European sanctions enforcement: the custodial sentences

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.

Finland – Customs has more than 800 sanctions investigations

Finnish Customs has given an update on trade sanctions enforcement in Finland. The press release confirms that there are more than 800 such investigations being undertaken by Finnish Customs of which around 90 are being investigated as aggravated offences.

Oddly, a press report, published on the same day, reported that Finnish Customs had more than 740 ongoing investigations. The figure of 740 had been reported back in April, as per our earlier post, itself an increase on the figure of 700 investigations reported in February.

The press release from Finnish Customs also gave detail of a particular investigation into a customs warehouse company in eastern Finland suspected of exporting drones, processors, smartphones, computers and echo sounders to Russia.

The goods arrived in Finland as air freight at Helsinki Airport, after which they were attempted to be exported via the company’s intermediate storage in Virolahti by road to Russia.

The value of the sanctioned goods was about €700 000 and are said to have mostly been ordered from online stores in the US with the consignee in Russia as the Russian postal service.

To date seven people have been questioned as part of the investigation.

Finland – three Russian nationals under investigation for dual-use exports

Further to our earlier post from May when three Russian national university students were arrested in Finland, an update on the case has now been reported.

The investigation of all three individuals continues, with two having been released from custody over the summer and the third recently released.

The conditions of bail include a travel ban, and it is said that the three are being investigated in relation to the “gross regulatory crime” of exporting dual use goods from Finland to Russia in breach of EU sanctions.

It is unclear whether this case is related to Tampere University recently reporting itself to the Finnish police.

Finland – university calls in police to investigate suspected breach of sanctions

It is being reported that the University of Tampere in Finland has asked the police to investigate a suspected breach of sanctions “at the institution”.

The suspicions relates to potential breach of sanctions as well as export controls on dual-use goods. The particular sanctions regime involved is not specified in the material that is public.

Little other information is available including whether the suspicions relate to staff or students.

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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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