Finland – European Sanctions Enforcement

November 15, 2024November 15, 2024 by Mark Handley

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:

Netherlands – 2 years: https://blogs.duanemorris.com/europeansanctionsenforcement/2017/03/14/netherlands-two-year-sentence-for-breach-of-al-qaida-sanctions/
Netherlands – 19 years (although this sentence included numerous other offences): https://blogs.duanemorris.com/europeansanctionsenforcement/2017/04/21/netherlands-19-year-jail-term-upheld-on-appeal/
Italy – 2 years: https://blogs.duanemorris.com/europeansanctionsenforcement/2017/05/03/italy-two-year-sentence-for-arms-exports-to-libya-and-iran/
Italy – two individuals given 3 years and 8 months and 3 years and 6 months respectively: https://blogs.duanemorris.com/europeansanctionsenforcement/2017/07/13/italy-sentences-for-arms-exports-to-iran-and-libya/
Netherlands – 16 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2017/09/04/netherlands-fine-and-custodial-sentence-imposed-for-breach-of-iran-sanctions/

2018:

United Kingdom – 2.5 years: https://blogs.duanemorris.com/europeansanctionsenforcement/2018/11/22/uk-three-convicted-of-exporting-military-goods-to-iran/

2019:

Belgium – 12 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2019/02/07/belgium-convictions-for-breaching-syrian-sanctions/
Netherlands – two individuals given 1 month each: https://blogs.duanemorris.com/europeansanctionsenforcement/2019/02/18/netherlands-two-companies-and-three-individuals-convicted-of-iran-exports/
Netherlands – 12 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2019/11/05/netherlands-conviction-for-breach-of-isis-sanctions-2/

2020:

Germany – 7 years: https://blogs.duanemorris.com/europeansanctionsenforcement/2020/01/09/germany-seven-year-sentence-for/

2021:

Germany – 3 years and 9 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2020/01/09/germany-seven-year-sentence-for/

2022:

Netherlands – 6 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2022/02/04/netherlands-6-month-custodial-sentence/
Netherlands – 1 year and six months: https://blogs.duanemorris.com/europeansanctionsenforcement/2022/06/28/netherlands-18-month-sentence-for-exports-to-iran/
Netherlands – 2 years and 6 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2022/08/31/netherlands-30-month-custodial-sentence-for-breach-of-isis-sanctions/
Germany – 1 year and 7 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2022/11/17/germany-conviction-for-importing-timber-from-myanmar-referred-to-cjeu/

2023:

Germany – 5 years: https://blogs.duanemorris.com/europeansanctionsenforcement/2023/08/30/germany-conviction-for-exporting-drone-parts-to-russia/
Netherlands – 1 year and 6 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2023/11/01/netherlands-custodial-sentence-and-corporate-fine/

2024:

Finland – 40 days: https://blogs.duanemorris.com/europeansanctionsenforcement/2024/02/14/finland-conviction-of-russian-national-for-breach-of-the-eu-travel-ban/
Netherlands – 4 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2024/04/19/netherlands-four-month-prison-sentence-for-breach-of-isis-sanctions/
Germany – 6 years and 9 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2024/07/18/germany-two-individuals-convicted-of-electronics-exports-to-russia/
Netherlands – 4 years: https://blogs.duanemorris.com/europeansanctionsenforcement/2024/09/12/netherlands-conviction-for-breach-of-isis-sanctions-upheld-by-court-of-appeal/
Netherlands – 2 years and 8 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2024/10/07/netherlands-two-years-and-eight-months-sentence-for-exporting-sanctioned-goods-to-russian-airlines/
Germany – 7 years: https://blogs.duanemorris.com/europeansanctionsenforcement/2024/11/08/germany-seven-year-sentence-for-exports-of-military-and-dual-use-goods-to-russia-and-confiscation-of-profits/
Netherlands – 1 year and 3 months: https://blogs.duanemorris.com/europeansanctionsenforcement/2024/11/11/netherlands-conviction-and-confiscation-for-exporting-sanctioned-goods-to-russian-companies/

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.

October 21, 2024October 21, 2024 by Mark Handley

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.

October 15, 2024 by Mark Handley

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.

October 10, 2024October 10, 2024 by Mark Handley

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.

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.

April 22, 2024 by Mark Handley

European Sanctions Enforcement – milestone of over 2000 announced and active investigations reached

With the recent news that Finland has increased the number of its ongoing investigations, Europe (meaning the EU, the UK, Switzerland, etc) has reached the milestone of over 2,000 ongoing and public sanctions enforcement investigations being undertaken by regulators and prosecutors.

No doubt there are other investigations which are ongoing in the countries shown on the graph, and no doubt there are investigations ongoing in countries not shown and which remain confidential.

How many of these will be dropped due to inconclusive evidence or exculpatory evidence, and how many will lead to a conviction or fine or acquittal is impossible to say.

It is, without question, an unprecedented level of enforcement.

April 22, 2024 by Mark Handley

Finland – 40 further EU Russian trade sanctions investigations commenced

At the time of our earlier post in February the Finnish authorities were stating that they had 700 ongoing investigations into alleged breaches of the EU’s trade sanctions against Russia.

It is now being reported that they have “over 740” preliminary investigations into such breaches which suggests that a further 40 investigations have commenced in the interim.

No further details have been published on these new investigations.

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 7, 2024 by Mark Handley

Finland – conviction (and acquittals) for exports to Russia

It has been reported today that French national Gabriel Temin has been convicted in Finland for exporting military goods to Russia in breach of EU sanctions.

He was given a suspended 9-month sentence and fined €11,000.

He was acquitted on a number of other more serious charges, and other defendants were acquitted as well. The prosecution had alleged that nearly 3,000 drones had been exported to Russia, but the court found there was insufficient evidence for this. The sale was to a customer in Kazakhstan and there was only circumstantial evidence that the goods had been retained in transit within Russia.

February 19, 2024 by Mark Handley

Finland – 700 Russian trade sanctions investigations of which 70 are large and complex

In September 2023, the Finnish Customs authorities announced they had 600 ongoing criminal investigations of which 60 were “aggravated”.

As reported in Wirtschaft Woche Sari Knaapi , the Chief Economic Crimes Investigator at Finnish Customs has now given details of the current figures, stating that there are now 700 ongoing investigations, with around 70 that are described as “large, complex cases”.