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.


Latvia – investigation into bunkering vessel refueling Russian “shadow fleet”

A vessel owned by a Latvian company is providing bunkering (i.e. refueling) services to the Russian “shadow fleet” in the Baltic sea off the coast of Gotland in Sweden.

A spokesman for the Latvian Foreign Ministry has stated that an investigation is now underway to see if the Latvian company is breaching or circumventing EU sanctions, in particular whether the fuel being supplied is of Russian origin.

The Latvian company, Fastbunkering, denies breaching sanctions.

It is noteworthy that just two days ago the Swedish authorities were reported as having closed an investigation into these same possible breaches of sanctions.

A Swedish prosecutor was reported as having stated: “I have made the assessment that it is not worth requesting legal aid from Latvia because it is not expected to lead to a higher penalty than a fine“.

Latvia – criminal investigation into helicopter sale discontinued

It is being reported that the Latvian State Security Service (the VDD) has discontinued a criminal investigation started in November 2023 into the sale of a helicopter by a company indirectly co-owned by the designated person Petr Aven .

The sale had been reported to the VDD by a court-appointed bailiff on suspicion that the sale (which took place as part of an insolvency proceeding of the helicopter owning company) may be being used as a tool to circumvent the relevant asset freezes imposed by the EU.

The investigation included the questioning of a number of witnesses, and the freezing of the sale proceeds.

The VDD has concluded that the insolvency was proper, that the loan agreement which funded the helicopter purchase pre-dated the imposition of sanctions, and that the debts of the company could be discharged from the sale proceeds

Latvia – arrest on suspicion of breaching US sanctions

The US Department of Justice has issued a press release confirming that the Latvian authorities have arrested a 55-year old, Oleg Chistyakov.

He has been charged with multiple counts of breaching US sanctions and other offences as part of an alleged wider conspiracy with two other also-charged individuals to supply avionics materials to Russia in breach of US sanctions.

The man was arrested near Riga on 19 March pending proceedings for extradition to the United States.

Latvia – 7789 Russian and Belarusian sanctions breaches detected

The Director of the Customs Administration within the Latvian State Revenue Service (VID) has been reported as saying that a total of 7,789 violations of sanctions imposed on Russia and Belarus were detected during 2023.

It is unclear what the Customs Administration did with these detected breaches, and whether those involved were investigated, charged or prosecuted.

We have previously reported that Latvia has, to date, commenced 310 criminal prosecutions and obtained a total of 7 convictions for sanctions offences.



Latvia – sanctions raids and inspections into Russian timber imports

The Latvian State Security Service has today announced multiple raids and inspections took place last week in relation to an ongoing criminal investigation into plywood imports into Latvia where counterfeit documents mask the Russian or Belarusian origin of the products in favour of false origins in Kazakhstan and Kyrgyzstan.

The importation of many timber products is prohibited under the EU’s Russian sanctions.

The report notes that the criminal proceedings were commenced in November 2023.

It is unclear whether this investigation in Latvia is related to a similar investigation into plywood imports being undertaken in Lithuania. See our earlier post.

UPDATE: The Latvian VDD has now provided some further clarification of the location of the raids including the premises in Valmiera of the Latvian Chamber of Commerce and Industry.

Latvia – further sanctions enforcement statistics including seven convictions

The Latvian authorities have provided a further update to their enforcement efforts. As reported:

    • 281 sanctions-related suspicious activity reports in 2022
    • 510 sanctions-related suspicious activity reports in 2023
    • 310 criminal cases commenced
    • 22 prosecutions in which the trial has started
    • 7 convictions to date.

Of the convictions, all involved guilty pleas and all involved Latvian nationals. The highest penalty related to the export of a luxury car, and the fine was €170,000.

The conduct prosecuted included in relation to the sale of a professional footballer to a club owned by a company designated under Belarus sanctions, and the provision of content to the Russian Federal News Agency.

UPDATE: It has now (18 March 2024) been reported that the fine imposed in relation to providing economic resources to the Russian news agency in the form of employment services, was €15,500.

Latvia – announcement of 258 ongoing criminal prosecutions

In an earlier post we reported that the Latvian authorities had 14 ongoing criminal prosecutions.

This morning, Raimonds Zukuls of the Latvian State Revenue Service has given an interview announcing that 114 criminal cases were opened during 2022 and a further 144 cases were opened during 2023.

These cases all concern the EU’s Russian and Belarusian sanctions. It was also said that most cases relate to electrical goods, car parts, luxury goods, timber products, fuel, fodder and metal products.

It was also stated that over 5,000 imports/exports had been stopped by the State Revenue Service.


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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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