Finland – suspended sentence on conviction for dual-use exports to Russia

It is being reported, that after pleading guilty to charges of exporting dual-use goods to Russian in breach of the EU’s sanctions, a 20-year old student has been given a 14-month suspended sentence.

The student exported dual-use drones, laptops, computer processors, smartphones and laser rangefinders valued at nearly €74,000.

Further to our earlier post, two other accomplices were also arrested in May 2024 and have been investigated for exports valued at another €70,000.

As well as pleading guilty the student is said to have co-operated with the investigation. The outcome relating to the other two defendants is not yet known.

Finland – 26 investigations into breaches of trade sanctions started in 2025

Further to our earlier post regarding Finland’s hundreds of sanctions investigations, we are pleased to acknowledge the help of Finnish Customs in supplying newly-updated information on the investigations so far commenced for breaches of the EU’s trade sanctions. These figures do not include investigations relating to financial sanctions.

While information on the penalties/sentences imposed is not available it can be noted that:

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

The updated figures include concluded enforcement actions up to 17 September 2025, and include some revisions to the previously supplied data for the previous years.

As previously noted the reduction in the punishment of petty regulation offences between 2023 and 2024 is most likely to be attributed to the closures of the land crossings into Russia.

YearPetty Regulation OffenceRegulation OffenceAggravated Regulation OffenceTotal
202210416339306
20233538158492
20245593599
2025215926
Total464318141923

Finland – CEO acquitted of sanctions charges

The result of a prosecution of a company’s CEO has been reported in the Finnish press.

The company received an order from a Russian customer for non-prohibited goods. The products then became sanctioned leading to a dispute as to whether the contract should be performed. The Russian customer threatened to bring a claim if there was no delivery.

The Finnish company’s CEO decided the best path was to go through some of the motions of an export, which would then be blocked, and this would be proof that delivery could not be made.

The company made an export declaration for the goods (motor switches), and it was at this point that the flaw in the plan became apparent.

Customs considered that the company was seeking to export sanctioned goods and investigated and charged the CEO with the appropriate sanctions breaches.

Luckily for the CEO the District Court of South Karelia this week has acquitted the CEO. The court relied on the fact that the company had taken no steps to move the goods from its warehouse, and the court found that there was no real intention to actually export.

I am very grateful to Aleksi Pursiainen, of Solid Plan Consulting, for drawing this case to my attention.

If ever there was a cautionary tale on the drastic consequences that can come from not having appropriate sanctions wording in your contracts, this is it.

Finland – investigation commenced into Helsinki logistics company for sanctioned exports to Russia

Finland’s Customs has issued a press release announcing the an investigation into a company in the Helsinki region that is suspected or arranging exports of goods to Russia via third countries including Lithuania, Bulgaria, Poland, Belarus, Kazakhstan and Kyrgyzstan.

The exports are suspected of ranging from 2022 to 2025, and to have included direct sales by the company.

The goods involved are ball bearings and industrial motors with an estimated value of €300,000.

The investigation appears to have been started with the interception of a consignment of prohibited dual-use goods which was being directly exported from Finland to Russia.

Finland – Customs investigation into suspected electronics exports to Russia

On Thursday Finland’s Customs announced details of an ongoing investigation into a suspected aggravated offence of breaching the EU’s sanctions. This is the most serious category of offence under Finnish law.

Customs are investigating a company from eastern Finland alleged to have sold electronic parts and components (semiconductors, microchips, processors and connectors) to Russia valued at approximately €2.7m.

The two main suspects are a father and son, with the son currently serving in the Russian army.

The products are alleged to have been shipped via several different routes including via other EU countries, Hong Kong, direct to Russia, and others seemingly collected in Finland.

A tax investigation is also under way.

Prior to 2022 the company’s business is said to have been dedicated to tourism and the sale of art.

Finland – investigation into suspected nuclear-related breach of Russian sanctions

Finland’s Customs have issued a press release making public an investigation into the suspected export of technical documents from a nuclear power plant construction project to Russia.

The unnamed manging director of the company responsible for the construction project is identified as the person suspected of the offence.

The press release notes that the investigation is coming to an end and that, as yet, no decision on charging the individual has been made.

Finland – regulator’s audit findings on S-Bank’s sanctions compliance

Finland’s Financial Supervisory Authority has published the results of an “audit” on S-Bank PLC’s compliance with the EU’s Russian sanctions.

The audit revealed a “very significant lack” of effective controls in terms of the deposit limits imposed by the EU’s sanctions. Also highlighted was a lack of training and a lack of “sufficiently effective procedures” for sanctions compliance.

The audit also noted that there was a lack of independent supervision of business units with risk control sitting within each unit and being involved in the initial business decisions and so were unable to provide an independent check on those decisions.

Overall the audit findings were described as being of “high significance”, but it is unclear what further regulatory action might be taken.

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 providing figures for these investigations.

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 the investigations were started and the category of offending that was being investigated.

YearPetty Regulation OffenceRegulation OffenceAggravated Regulation OffenceTotal
202210415844306
20233548664504
20245593599
Total463303143909

The drop off 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“.

© 2009- Duane Morris LLP. Duane Morris is a registered service mark of Duane Morris LLP.

The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

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