Germany – publication of the latest 6-monthly sanctions enforcement update

The German authorities have published the third instalment of their 6-monthly updates on their current enforcement actions.

The report highlights:

  1. The conviction on 2 March 2026 of two individuals relating to the export of 111 luxury cars to Russia, with €20m confiscated, and jail sentences of 6 years and 2 years (the latter suspended). See our previous post.
  2. Raids conducted in November 2025 and the ongoing investigation into the suspected export of machine tool to Russia value at €1.7m. The report confirms that the investigation by the Stuttgart Public Prosecutor’s Office and the Stuttgart Customs Investigation Office remains ongoing. See our previous post.
  3. An investigation into five suspects for the organized circumvention of sanctions against Russia. A company is alleged to have exported technical equipment and accessories worth c. €689,000 to a company in Russia via third countries. The investigation started in February 2025 and is being conducted by the Essen customs investigation office, is ongoing. See our previous post.
  4. The prosecution of a 41-year old suspected of exporting 236 cars to Russia valued at approximately €18.86m. See our previous post.
  5. The arrest of five suspects on 2 February suspected of 16,000 illegal deliveries to 24 listed Russian arms companies of good worth at least €30m. The prosecution was supported by the Federal Intelligence Service (the BND). See our previous post.
  6. On 27 March raids conducted on 14 premises in the Rhine-Main region against two companies suspected of exporting machine parts and chemicals to Russia. A third company is said to have been involved in the alleged use of a transport and logistics companies to try and circumvent the EU’s sanctions. See our previous post.
  7. The ongoing investigation into a member of the Saxon state parliament for allegedly falsifying the export declaration in relation to a telescopic handler rather than stating the correct destination of Belarus. Searches were conducted at residential and business premises. See our earlier post.

The update also reports on a decision of the CJEU from 5 February 2026 upholding the seizure by German customs of a Mercedes car purchased in Russia and imported to Germany. The CJEU held that the single specific import did not need to “generate significant revenue for the Russian state”, so long as the general category of goods did.

Further cases noted previously in the blog over the last few months, but not included in the report are:

  • an investigation from February 2026 in relation to the import of goods valued at over €4m from Russia;
  • an investigation made public in January 2026 into the use of RussPost to export goods to Russia;
  • reporting from January 2026 into a mutual legal assistance request made to Ukraine as part of an investigation into the suspected export of drone parts to Russia;
  • the arrest in January 2026 of two people on suspicion of making available funds and economic resources to the Donetsk and Luhansk People’s Republics;
  • an investigation made public in December 2025 by the Munich Prosecutor’s Office into alleged export of 50 luxury cars valued at over €10m; and
  • raids in November 2025 in relation to the suspected export of 346 cars to Russia.

Spain – prosecution for military exports to Russia

It is being reported that the Spanish authorities are bringing a criminal prosecution for suspected exports of military aircraft engines to Russia in breach of the EU’s sanctions.

One individual, Olga V, has been in custody since her arrest in 2023. Another individual, Kostiantyn Antonovich Kucher, former Ukrainian Deputy Minister of Industrial Policy, is in detention in Azerbaijan pending extradition proceedings to bring him to Spain.

It is alleged that the two, and a network of companies (including Aero Design Systems and Global Force Technology), sought to export aircraft engines to Russia including to the United Aircraft Corporation.

The investigation has included the seizure of three engines by German customs.

Belgium – prosecution for alleged sanctioned exports to Russian military

Following a raid conducted in June 2025, the Belgian authorities have detained Russian national Viktor Labin pending investigation of alleged breaches of Russian sanctions.

It is now being reported that trial in the prosecution is scheduled to begin on 26 February 2026.

It is alleged that he was responsible for exporting machinery and devices for use by the Russian military or in manufacturing.

United Kingdom – company director convicted and sentenced for exports of military-grade rifle sights to Hong Kong

The UK’s HMRC has issued a press release announcing the conviction and sentencing of Steven Gates for unlicensed exports of eight military-grade rifle sights to a buyer in Hong Kong.

Customs declarations were also falsified to say the sights were camera equipment.

One export was prevented in February 2022 by Border Force staff at Manchester Airport, and another in April 2023.

Searches at his house revealed evidence of another 10 exports.

Mr Gates has been sentenced to jail for 2 years and one month.

Importantly, the press release notes that HMRC is “pursuing 51 criminal investigations in 2024/2025 compared with give in 2021/22”.

Germany – raids and five arrested as part of alleged Russian procurement network

Germany’s Federal Prosecutor’s Office has issued a press release detailing that the German authorities this morning have arrested 5 individuals as part of raids on premises in Lübeck, Frankfurt am Main, and Nuremberg.

Five of the suspects are named as Artem I, Boris M, Eugen R, Nikita S and Daniel A. Five suspects remain wanted.

The allegation is that a German company based in Lübeck has made 16,000 deliveries to 24 different Russian defence companies with the goods valued as at least €30 million. The category of goods is not specified.

Germany – investigation into company alleged to have supplied materials for Russian drones

It is being reported that a mutual legal assistance request has been sent by German authorities to Ukraine investigating press reports of German companies alleged to have supplied materials used in the building of the Shahed drones used by Russian in the conflict with Ukraine.

The German company reported to be the target of the information gathering is Goettle Advanced Products GmbH & Co. KG and possible connections to the Russian manufacturer Composite Products LLC.

Latvia – prosecution for ammunition export to Russia

Latvia’s Prosecutor’s Office has issued a press release regarding bringing a criminal prosecution before the Riga City Court against an Estonian-Russian dual national for attempting to transport 10,000 items of ammunition into Russia.

The shipment was stopped at the Terekhov Customs crossing. As part of a search of the truck the bullets were found hidden within the driver’s cab of the truck.

Sweden – Customs board distressed Russian vessel in Swedish waters

After a Russian vessel had engine trouble and entered Swedish territorial waters, Swedish Customs boarded the vessel and commenced an investigation into whether possible sanctions or export control offences may have been committed.

The vessel, the Adler, is designated under EU sanctions, and the owner sanctioned by the US. It is reported that the cargo included arms and military equipment.

It is now being reported that the vessel has been allowed to depart Swedish waters, after the Prosecutor’s Office declined to open a criminal investigation, on the basis that there was no intent to bring the vessel or its goods into Sweden.

© 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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