It is being reported (here and here) that the European Public Prosecutor’s Office has conducted a raid on the premises of Bulgartransgaz in Bulgaria.
The investigation is said to concern whether natural gas supplied via the Turkish company Botas may include gas of Russian origin and be being done in circumvention of the EU’s Russian sanctions.
This would be the first public and specific investigation by the European Public Prosecutor’s Office into allegation of sanctions breaches.
A press release from the United State’s Attorney’s Office for the Southern District of New York has included details of an arrest and extradition by the Cypriot authorities in support of US charges of sanctions and export control violations.
On 26 August 223, Arthur Petrov was arrested in Cyprus in relation to:
“export control violations, smuggling, wire fraud, and money laundering offenses in connection with his alleged participation in a scheme to procure U.S.-sourced microelectronics subject to U.S. export controls on behalf of a Russia-based supplier of critical electronics components for manufacturers supplying weaponry and other equipment to the Russian military”.
Mr Petrov operated the scheme through his Cypriot company Astrafteros Technokosmos LTD.
His extradition from Cyprus was completed and he arrived in the US on 8 August 2024.
The Lithuanian Customs Service has issued a press release regarding a fine of €13,618,175 imposed on a company.
The company had exported vehicles to Russia through third countries Belarus, Kazakhstan and Turkey.
Six tractor semi-trailers were also confiscated.
Although the Customs press release does not name the company, press reports have identified the company as Biovarda based in Vilnius.
The press release also states, opaquely, that “After the Lithuanian customs started to apply stricter inspection measures, it is not the first time that such sanctions have been applied to companies for violations of the Law on International Sanctions”. No ore detail on these other enforcements was provided.
Luxembourg’s Financial Intelligence Unit (the CRF) has published its Annual Report which includes statistics on sanctions-related SARS and investigations, as well as an indication of funds frozen as part of these investigations.
It is being reported that the UK’s National Crime Agency has completed the confiscation of funds related to Petr Aven.
The sum of £750,000 was confiscated from bank accounts held in the name of Petr Aven’s wife and others.
A sum of cash initially recovered by the NCA from a residence outside London was also confiscated.
The funds were confiscated under the Proceeds of Crime Act 2002.
Updated on 1 August to reflect issuance of NCA’s press release:
The NCA has stated that the funds, totalling £783,827.34 were held for the benefit of Petr Aven although not in his name, and that the breaches of sanctions giving rise to the funds being the proceeds of crime were: “Attempts to relocate the funds, as well as transactions made after March 15 2022 by Aven’s estate manager, Stephen Gater … . These included the payment of salaries to over 20 members of Aven’s household staff, and the sale of a Bentley Bentayga worth £160,000“.
It is being reported that two law firms have been reported by the Solicitors Regulation Authority (SRA) to the UK’s OFSI.
it is alleged that the law firms were facilitating financial transactions valued at more than £300,000. It is unclear whether the conduct relates to designated persons, trade sanctions, or the UK’s prohibitions on Russian investment.
The attention on law firms chimes with the report yesterday that there has been an investigation in Germany relating to a potential breach of the EU’s prohibitions on legal advice.
The German media outlet Südwestrundfunk has conducted a survey of Germany’s state justice ministries, public prosecutors office and the Federal Prosecutor’s Office to compile statistics on recent sanctions investigations in Germany.
The vast majority of these are said to relate to Russian and Belarusian sanctions although enforcement of other regimes is included.
The results are:
This is a total of 1,988 investigations conducted since 24 February 2022. No data were reported for the states of Lower Saxony or Anhalt, so this figure is not complete.
In September last year (see earlier post) it was reported that there were 150 on-going investigations in Germany. The new survey reports a minimum of 176 investigations now reported as ongoing, although many regions did not provide a figure for currently ongoing investigations.
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.
Switzerland’s SECO has updated its Russian and Belarusian sanctions enforcement statistics. The previous update was in February 2024 (see our previous post).
The reported new data states that SECO has brought:
Accordingly, SECO has started 9 new criminal administrative proceedings since February 2024, and imposed 5 new fines since May of this year.
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.
