Germany – investigation into alleged sanctions breaches by Roman Abramovich

It is being reported that investigations have been commenced in Germany in relation to suspected sanctions breaches by Roman Abramovich.

Actions by the Federal Criminal Police Office and the Central Sanctions Enforcement Office have included raids on properties and the confiscation of luxury cars and artwork.

The suspected breaches of Regulation 269/2014 are the failure to properly or adequately disclose his frozen assets, including a 19th-century villa in Garmisch-Partenkirchen

It is also being reported that Mr Abramovich’s lawyer has said that he is not the ultimate owner of the villa or the confiscated luxury cars.

Lithuania – sanctions raids, arrests and seizures related to trucking companies

It is being reported that the Lithuanian Customs Criminal Service has conducted raids at multiple addresses in Vilnius and Rudamina, has arrested four individuals (2 Belarus nationals and 2 Lithuanian nationals), and seized 33 vehicles valued at €1.5 million.

The vehicles are 17 trucks, 15 semi-trailers and a mini-bus, which are said to have been involved in alleged trade with Russia and Belarus in breach of the EU’s sanctions.

The first round of raids were conducted on 29 January with further raids since then.

Estonia – 83 criminal prosecutions for Russian trade sanctions violations since 2024

It has been reported that during 2024 Estonia’s Internal Security Service commenced 71 criminal cases in relation to suspected trade with Russia in breach of the EU’s sanctions, and has commenced another 12 already during 2025. These cases are said to be for the more serious, intentional or repeat offenders.

The same report note that Estonia’s Police and Border Guard Board are currently identifying an average of 12 sanctions violations per day predominantly by individuals attempted to take cash or luxury goods into Russia. This is reported to be down from a previous average of 22 violations per day.

With all people crossing the border being subject to inspection, first time offenders are required to either turn back and not cross, or to accept confiscation of the goods/items and continue the journey.

United Kingdom – OFSI reveals 706 Russian sanctions investigations opened since February 2022

As first brought to wider attention by the Global Sanctions site, the UK’s Economic Secretary has provided a written answer on the UK Parliament’s website to the question: “how many investigations by the Office of Financial Sanctions Implementation into breaches of Russian sanctions (a) are open and (b) have been undertaken since February 2022“.

The answer stated that 388 cases have been investigated by OFSI and closed since February 2022, and that 318 investigations are currently open.

This is a total of 706 investigations opened by OFSI into potential or alleged Russian sanctions breaches in the UK since February 2022.

In that time OFSI has imposed two fines (here and here) in relation to Russian sanctions and disclosed one other breach by Wise Payments Limited (here).

This means that 385 of OFSI’s opened Russian investigations since February 2022 were closed without further action.

As of April 2023, OFSI was reporting it had 172 lives cases ongoing, indicating that there has been a significant increase since then.

Germany – raids and arrests of suspected exporters of luxury cars to Russia and Belarus

It is being reported that on 16 January raids were carried out at six addressed in Ludwigshafen, Schifferstadt and Mannheim and a 53-year old was arrested on suspicion of exporting over 150 luxury cars to Russia and Belarus valued at more than €7,500,000.

Cash and cars valued at more than €500,000 were seized and accounts frozen.

The same article reports on another case from November 2024 (also reported here), in which a 26-year old was arrested and detained on suspicion of exporting 30 luxury cars to Russia valued at around €3,500,000.

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 those figures.

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 it commenced its many investigations and the category of offending that was being investigated.

YearPetty Regulation OffenceRegulation OffenceAggravated Regulation OffenceTotal
202210415844306
20233548664504
20245593599
Total463303143909

The drop off in investigations 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.

Lithuania – raids and 10 arrested for suspected prohibited exports to Russia

Lithuania’s State Security Department has issued a press release detailing raids and arrests carried out on 14 January of this year involving ten suspects.

The investigation was said to have been a collaborative effort also involving Estonia and Latvia.

The principal suspect is a Russian national who is alleged to have orchestrated the supply of high-tech equipment manufactured in Lithuania to Russian customers related to the Russian defence and security industry. He remains in custody. The other suspects have been released subject to conditions.

A pre-trial investigation has been commenced by the Vilnius Regional Prosecutor’s Office in relation to the suspects.

United Kingdom – HMRC unaware of how many sanctions investigations it is currently conducting

Sky News in the UK has made a Freedom of Information Request to the UK’s primary trade sanctions enforcement body, His Majesty’s Revenue and Customs (HMRC), asking for the “number of cases you are currently investigating”.

See the Sky News piece here (including some comments from Mark Handley of this blog).

HMRC has responded (available here and with thanks to Sky News for providing a copy).

It has said that “the number of current investigations … is not centrally recorded. To determine how many investigations are within scope of your request would require a manual search of a significant number of records, held by different business areas“.

Sky News also asked about the identities of the entities or individuals which have received the six compound penalties for breaches of the UK’s Russian sanctions.

In line with HMRC policy this information was not disclosed because “HMRC do not consider that disclosing the company name would drive compliance, promote voluntary disclosure or be proportionate“.

While this has long been HMRC’s policy, the stance of OFSI and the new Office of Trade Sanctions Implementation is that they will each name the companies subjected to fines.

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.

United Kingdom – National Crime Agency gives update on sanctions enforcement

As first reported by the BBC, the National Crime Agency has written to the Chair of the Treasury Committee of the House of Commons to respond to a series of questions about the NCAs sanctions enforcement efforts to date.

The letter confirms that there have been no convictions obtained under Russian sanctions, or indeed any sanctions regime since the coming into force of the Sanctions and Anti-Money Laundering Act in January 2021.

The NCA also stated that “a very small proportion” of its workload is sanctions-related, but it would not disclose how many cases had been referred to it by OFSI or any other body, or how many active investigations followed from the 5,600 sanctions-related suspicious activity reports it received in the year 2022-2023.

The letter also stated:

the NCA’s Combatting Kleptocracy Cell (CKC) has delivered over 150 disruptions, which include: asset freezes and forfeiture, taking action against key enablers, and supporting international partners” and then gave a number of specific examples including the successful forfeiture of £780,000 obtained in July 2024.

Another example given was “The arrest of enablers in the regulated sector who support the transactions of corrupt elites“, although no further detail was provided.

© 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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