It is being reported that Polish authorities have arrested and charged a German national with exporting dual-use technology to Russia in breach of EU sanctions.
The arrest was in the Lubusz province and relates to the export of machinery which can be used in weapons manufacture. It is also said that the exports were directed at “Russian military plants involved in weapons production”.
The individual is reported to have admitted his guilt.
It is being reported by Reuters that the Polish state-owned company WSK Poznan is being investigated by the National Prosecutor’s Office and the Internal Security Agency on suspicion of supplying parts to Iranian manufacturer, Motorsazan Company, which were then incorporated into drones used by Russian combat forces in Ukraine.
The National Prosecutor’s Office is also reported to have charged the CEO of the company in relation to the export of dual-use goods.
Another report states that the investigation has been ongoing for two years, and notes that the Polish National Prosecutor has denied evidence that parts were used for drones and stated that the investigation relates more to the sale of fuel pumps to Iran.
The Polish authorities have released updated enforcement statistics showing changes since those release just a few weeks ago.
The new data confirms:
Further, in response to a Freedom of Information request made on behalf of this blog, the Polish Ministry of Finance has provided the following data (available here: MF do M. Handley’a odpowiedź na wniosek 2879.2024):
No other European country has imposed so many fines for breaches of Russian sanctions.
As part of the press article (behind a paywall) on the recent fines against Novatek Green Energy and Geleo (see our post here), the Polish authorities have also provided an update on their enforcement activity more broadly.
Certainly the figure for total fines does not include the fine against Novatek Green Energy (which was 12 million zloty), but it is also a little unclear whether or not the figure includes the fine against Geleo (which was 4m zloty).
The report also notes that most of the 20 penalties have been imposed in 2024, with only two imposed by the end of 2023 for a combined total of 71,000 zloty (c. $17,700).
These enforcement actions appear to relate to a mix of EU and the separate Polish sanctions.
No information has been provided as to the conduct which gave rise to the fines, or who the fines were imposed on.
Now updated from the post first published on 28 June.
It is being reported (behind a paywall) that the Malopolska Customs and Tax Office of Krakow has imposed fines of 12 million zloty (c. €2.78m) against Novatek Green Energy and 4 million zloty (c. €927,000) against employee-owned company Geleo.
The fine against Geleo was imposed on 31 May. It was for breach of the relevant asset freeze and for circumvention of Polish sanctions. The transaction in question was the purchase, for €1, of 100% of the shares in Novatek Green Energy from the Swiss company Novatek Gas and Power GmbH, which in turn is a direct subsidiary of the Russian company OAO Novatek.
The fine against Novatek Green Energy was imposed on 25 June, and was imposed for multiple transactions in breach of the imposed asset freeze.
With particular thanks to Dr Marcin Łukowski who provided a copy of the relevant article.
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.
After first being reported by Polish radio station Radio Zet, it is now being reported in the press that the Polish Special Services has commenced an investigation into whether the Swiss oil trading subsidiary of a state-controlled oil company has breached the EU’s Russian sanctions in relation to oil.
The Polish parent company is Orlen, which is 49% owned by the Polish state, and the Swiss subsidiary is Orlen Trading Switzerland.
It is alleged that the Swiss subsidiary was incorporated in Switzerland in late 2022 ahead of the relevant changes to EU sanctions which came into effect in early 2023 as a means of continuing to purchase and trade in oil of Russian origin.
The companies are reported as having denied the allegations.
It has been reported today that the Polish Interior Ministry has confirmed an investigation into the alleged importation of timber from Belarus.
The allegations include that the timber was accompanied by forged documentation purporting to show a Kazakhstan origin for the timber.
Other investigations into alleged imports of timber from Russia or Belarus in breach of EU sanctions are underway in:
It has been reported that the Polish authorities are currently investigating between 7 to 9 companies for potential breaches of the EU’s Russian sanctions.
The source for the information is a representative of Poland’s FIU reported in a report on Polish sanctions by the Royal United Services Institute.
