Russia – European Sanctions Enforcement

April 10, 2025April 10, 2025 by Mark Handley

United Kingdom – first criminal convictions under the UK’s Russian sanctions

It is being reported that the jury in the criminal prosecution of designated person Dmitrii Ovsiannikov, his wife Ekaterina Ovsiannikova, and his brother in law Alexei Owsjanikow have returned two guilty verdicts and one acquittal.

See our earlier posts on the progress of this case here and here.

These are the first criminal convictions obtained by the UK authorities under the UK’s Russian sanctions regime, and the first criminal conviction under any sanctions regime since 2017. It is also a rare example of the prosecution of a designated person.

Ekaterina Ovsiannikova was acquitted on four counts of circumventing sanctions arising from payments to her husband of £76,000 in 2023.

Alexei Owsjanikow was acquitted of several counts relating to access to a car, arranging car insurance and use of a bank account. He was, however, convicted of two counts of circumventing sanctions relating to the payment of £41,027 in private school fees.

Dmitrii Ovsiannikov was convicted of six of the seven counts he was charged with, all relating to breaches of the asset freeze imposed upon him by reason of his status as a designated person.

Sentencing will take place in due course, and it is to be hoped that the judge’s Sentencing Remarks are made public.

April 8, 2025April 8, 2025 by Mark Handley

Switzerland – Attorney General’s Office provides details on two ongoing criminal sanctions cases

The Annual Report of the Swiss Attorney General’s Office (OAG) contains details on two ongoing criminal sanctions cases which it has taken over from SECO. Both cases arise under Switzerland’s Russian sanctions.

In one the OAG state that they have conducted search at eight residential properties in the cantons of Lucerne, Zug and Nidwalden. The investigation is said to relate to both an asset freeze imposed on a designated person and suspected breaches of the Swiss Embargo Act.

Assets which are the subject of “super-provisional freezing” as part of this investigation are said to total CHF 1.3 billion (or c. €1.39 billion).

Less information is given on the second investigation other than that it is “in connection with suspected sanctions violations by a Swiss company via subsidiaries abroad”.

April 2, 2025 by Mark Handley

Germany – arrests, raids and asset seizures in two Russian car export investigations

The Customs Office in Frankfurt am Main has issued a press release relating to actions taken in two ongoing investigations.

The first case, which is being conducted by the Darmstadt Prosecutor’s Office, saw raids in Offenbach, Main-Taunus, Hochtaunus and Main-Kinzig under 24 different warrants. There are two defendants aged 58 and 81, and they are suspected of exporting cars to Russia in breach of sanctions as well as other offences. Cars, cash, coins, watches and real estate were seized with a value of €7.8 million.

The second case arose from a suspicious activity report, and is being conducted by the Frankfurt am Main Prosecutor’s Office. A 55-year old is suspected of having exported more than 150 cars to Russia in breach of sanctions. Raids were carried out in the district of Offenbach with evidence and assets seized. The press release states that the value of seized assets was €6.9 million.

April 2, 2025April 2, 2025 by Mark Handley

Switzerland – updated enforcement statistics with 9 new convictions since September 2024

Switzerland’s SECO has given an update on its ongoing enforcement actions.

It has received 600 reports of suspected sanctions breaches, and it has opened 68 penalty proceedings, of which 24 have resulted in final fines.

As per our earlier post, as of September 2024 the figure was at 15 final convictions, meaning that another 9 have been added since then.

No figure has been given for the penalties imposed.

April 2, 2025 by Mark Handley

Switzerland – update on ongoing criminal sanctions proceeding

Further to our earlier post from August 2024, the Swiss authorities have provided an update on one of their ongoing criminal sanctions investigations.

The investigation relates to people linked to Suleiman Kerimov, a designated person under Swiss sanctions.

As of August 2024 it was an investigation into four people, it is now being reported that the Swiss authorities have confirmed that the case has moved to an ongoing criminal proceeding, and that there are five individual defendants.

April 2, 2025 by Mark Handley

France – TV regulator orders satellite provider to stop broadcasting sanctioned Russian channels

The French media regulator , Arcom, has issued an order to Eutelsat ordering it to cease the broadcasting of two channels owned or controlled by JSC National Media Group which is a designated person under the EU’s Russian sanctions.

The channels are STS and Kanal 5.

Earlier reports had suggested that Arcom might impose a fine on Eutelsat, but no fine was imposed.

March 21, 2025March 21, 2025 by Mark Handley

United Kingdom – OFSI fines Moscow subsidiary of UK law firm £465,000

The UK’s OFSI has published a penalty notice imposing a £465,000 fine on Herbert Smith Freehills CIS LLP (“HSF Moscow”) – a UK LLP which operated as the Moscow office of the law firm Herbert Smith Freehills (“HSF”)

The fine was reduced by half due to prompt self reporting by HSF (all the breaches had been reported by 15 July 2022) and further co-operation in the form of the conduct of an internal investigation.

The breaches of the UK’s sanctions were all done by HSF Moscow between 25 and 31 May 2022. The breaches arose from six payments made to designated persons with a total value of £3,932,392.10. The six breaches were:

a payment into a bank account held at Sberbank (a designated bank) to clear an overdraft;
Payment of three invoices valued at £3,903.76 for insurance issued by Sovcombank Life, a wholly-owned subsidiary of Sovcombank (a designated bank);
Payment of £13,216.32 as a redundancy payment to an employee’s bank account held at Sberbank; and
Payment of £3,915,232.31 into an account held by Alfa-Bank (a designated bank), although the transfer was swiftly reversed.

This case emphasizes above all the approach that OFSI takes in relation to accounts held at designated banks. In the view of OFSI payments into such accounts, albeit accounts held by non-designated persons, will amount to making funds available to a designated person.

In relation to the payment to a subsidiary of a designated person, OFSI also emphasizes the importance of appropriate due diligence to understand possible issues of ownership and control.

March 21, 2025April 3, 2025 by Mark Handley

United Kingdom – enforcement update from the OFSI annual report for 2023/24

OFSI has published its annual report for the year 2023/2024.

The report provides the following data:

2021/22 – 147 investigations opened (and 101 closed);

2022/23 – 473 investigations opened (and 74 closed); and

2023/24 – 396 investigations opened (and 242 closed).

Of the 396 investigations opened in 2023/24, 288 were as a result of self-reporting with 108 opened through pro-active investigation or other means.

Further, OFSI’s report gives a break down of which sanctions regimes the investigations relate to:

347 to Russian sanctions;
21 to Libyan sanctions;
9 to Iran sanctions; and
19 across the other regimes.

The report also gives a break down of the 242 investigations closed during the year of the report:

133 closed with a finding of no breach and sending a “No Further Action” letter;
18 closed with a finding there was a breach and sending a “Warning” letter;
1 closed with a finding of a breach and a referral to a regulator;
1 closed with an OFSI public disclosure;
61 closed without a final determination that there was a breach and sending a “No Further Action” letter; and
28 investigations closed for “Other” reasons.

March 17, 2025 by Mark Handley

Germany – prosecution to proceed against individuals alleged to have exported machinery to Crimea

It is being reported that the Hamburg regional court has ordered that trial should proceed against two of the five individuals who being investigated for alleged exports of machinery to Crimea in breach of the EU’s sanctions.

As per our earlier posts (from 2024 and 2021 and 2018), the investigation relates to power generating turbines exported from Germany. Last year five individuals were charged.

The trial will now proceed against two of these with the court ruling that there was insufficient evidence against the other three. The prosecutor’s office has appealed the decision in relation to the other three.

March 13, 2025March 13, 2025 by Mark Handley

Germany – raids and arrests for suspected luxury car exports to Russia

It is being reported (here and here) that authorities in Berlin and Bavaria have conducted raids on five premises and arrested three individuals for the suspected export of nearly 200 luxury cars to Russia in breach of the EU’s sanctions.

The value of the cars is reported to be approximately €21 million, and they were exported via third countries such as Belarus, Uzbekistan and Tajikistan.