Trade Sanctions – European Sanctions Enforcement

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.

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.

March 13, 2025March 13, 2025 by Mark Handley

Latvia – prosecutions brought against four for exports to Russia

It is being reported that Latvia’s State Security Service has referred four individuals for prosecution for alleged exports of satellite communications equipment for the Russian military in breach of EU sanctions and other Latvian laws.

The investigation is ongoing and it is reported that other individuals are suspected of being involved.

The goods exported were Starlink Mini satellite communication systems.

March 5, 2025 by Mark Handley

Estonia – 8 sanctions convictions and more than 100 active criminal cases

The Yearbook of the Prosecutor’s Office in Estonia has published details on its enforcement of sanctions to date.

I thank Siiri Grabbi of the Coop Pank in Tallinn for the reference.

The Yearbook states that eight criminal convictions have been obtained with one also appealed. It does not provide details of the offending or the sentences imposed.

The Yearbook further notes that the Prosecutor’s office currently has more than 100 active criminal cases.

February 28, 2025 by Mark Handley

Poland – 275 ongoing sanctions investigations

It is being reported that the Polish authorities have responded to a press request by confirming that they have 275 sanctions investigations that are ongoing.

No further information was provided on these investigations. It is unclear how many of these relate to Russian sanctions.

February 28, 2025February 28, 2025 by Mark Handley

United Kingdom – HMRC has opened 65 trade sanctions investigations since 2022

In a letter written from the UK’s HMRC (the body with primary responsibility for the criminal enforcement of trade sanctions) to Parliament’s Treasury Select Committee, HMRC has provided significant information on its recent enforcement efforts.

Year	Number of investigations opened
2021	0
2022	14 (all relating to Russian sanctions)
2023	22 (20 relating to Russian sanctions)
2024	29 (27 relating to Russian sanctions)

Of those 65 investigations, HMRC has confirmed that 30 remain live of which 27 relate to Russian sanctions.

The letter tabulates the six fines imposed to date for breaches of the Russian sanctions, and in relation to the largest single fine of £1,000,000 imposed in August 2023 (see our earlier post), the letter notes that this fine relates to “brokering and technical assistance” and not to an actual export.

HMRC’s letter also states that a previously published compound penalty of £1,000 from September 2023 (see our earlier post) was actually for a breach of the UK’s Iran sanctions despite being described at the time as “relating to the attempted export of Dual Use goods”.

HMRC’s letter also states that in October 2024 it referred a case for possible prosecution to the Crown Prosecution Service.

February 28, 2025 by Mark Handley

Italy and Estonia – extradition of sanctions suspect to Estonia

It is being reported that the Estonian Prosecutor’s office has successfully completed the extradition of suspect Ivan Anchevsky, after he was arrested in Italy.

The prosecution of Anchevsky for suspected exports to Russian in breach of EU sanctions, forms part of a wider investigation including two unnamed Estonian companies and their boards of directors.

Anchesvsky, who is a citizen of both Estonia and Russia, is suspected of using his companies Melytec and Melytec Testing to export sanctions goods to Russia.