Germany – charges for dual-use exports to Russia

Further to our earlier post, the Federal Prosecutor’s Office has issued a press release confirming the indictment of Alexander S. on further charges relating to the export of dual-use goods to Russia in breach of EU sanctions.

The value of the exports is estimated at over €1 million.

The press release documents warning issued to Alexander S by the German authorities and his efforts to circumvent the prohibitions through falsifying documents and arranging for export from an Asian country.

Latvia – fines of €3.1m for breaches of Russian sanctions

Following raids in Riga and Tallinn by the Latvian Security Police, in close cooperation with the Estonian Internal Security Service (ISS), it was reported today that two individuals have been fined by the Latvian courts for breaching the EU’s Russian sanctions.

The breaches involved making funds available, through contracts involving broadcasting, to a designated person. The individuals (Oleg Solodov and Margus Merima) were each fined €25,000, and a further €3 million was confiscated.

Germany – five being investigated in relation to export of gas turbines to Crimea

It is being reported today that the Hamburg Public Prosecutor’s Office is currently investigating five individuals in relation to the export from Germany to Crimea of gas turbines manufactured by Siemens.

The broader investigation into the export of these turbines has been ongoing since 2018. See our earlier post.

Four of the individuals being investigated are German nationals, three of whom worked for Siemens in Russia, and the fifth is a Swiss national.

UK: OFSI’s second penalty for the day – Russian sanctions

OFSI has today issued a second penalty for breach of the EU’s Russian sanctions, again using its civil enforcement powers.

The penalty notice is available here.

The penalty, of £36,393.45, was imposed on Clear Junction Limited. The transactions in this case are the same as those relating to TransferGo, although OFSI makes clear that it was Clear Junction which reported the transactions. It is noteworthy that some of the impugned transactions took place after the first report to OFSI.

OFSI’s notice also makes the point that the breach here was of the EU’s Russian sanctions, and that post-Brexit OFSI will continue to investigate breaches of the EU’s regulations that may have taken place before Brexit.

UK – OFSI imposes civil penalty for sanctions breaches

Today OFSI announced it had imposed a £50,000 financial penalty on TransferGo in the latest example of the use of its civil enforcement powers.

OFSI’s penalty notice is available here.

The fine was imposed in relation to 16 transactions over nearly 2 years valued at just £7,674.77 through which funds were made available Russian National Commercial Bank, which is a designated person under the EU’s Russian sanctions.

TransferGo did not self report but did cooperate with the investigation.

OFSI’s notice makes clear that the RNCB was not the intended beneficiary of the transactions, rather the recipients of the transfers were accounts held by non-designated persons with RNCB. OFSI has made clear that as funds held in bank accounts are legally held by the banks, that these transfers all amounted to making funds available to RNCB

Germany – arrests for dual-use exports to Russia

The Federal Prosecutor’s Office has issued a press release announcing the arrest of an individual Alexander S on charges of exporting dual-use goods to military recipients in Russian in breach of EU sanctions.

Although the press release does not state as much, it is likely that this individual is the same as is already facing charges relating to earlier exports.

The arrest warrant alleges the export of dual-use high-quality machine tools to an end customer in the Russian defence sector.

Germany – convictions and fines for Russian exports

Further to our earlier post, it has been reported today that the Higher Regional Court in Hamburg has sentenced two men to prison for supplying machine tools to a Russian arms company.

The first defendant received a sentence of three years and nine months. In addition, almost €8 million in profits from the sale of the machinery will be confiscated

The second defendant was sentenced to two years’ probation for aiding and abetting with a payment of €150,000 to secure that probation. A further €184,000 are to be confiscated.

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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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