Netherlands – confiscation orders issued against company and individual convicted in 2024 of sanctions offences

Further to an earlier post relating to convictions of an individual and company obtained in October 2024 for supplying aircraft parts to Russian customers in breach of the EU’s sanctions, the Rotterdam Court has now ruled in the confiscation proceedings brought by the prosecution.

In the confiscation judgement against the (unnamed) company, the court ordered the confiscation of €165,826.

The court held that the revenue obtained from the sanctions breaches was €2,901,194, but allowed as “deductible costs” 82% of this amount, or €2,385,739. This is in line with the Dutch approach of allowing the convicted parties to break even on the unlawful transactions by confiscating not the illegally-obtained revenue (which the CJEU has held is a permissible approach), but rather the pure profit element.

The profit element was accordingly assessed as €515,455 which was divided between the convicted person and the convicted company.

In the second confiscation judgment against the individual, the same analysis was undertaken with the balance of €349,629 from the profits attributed to the individual. The judgment states that a further 599 days of jail time would be added to the existing sentence in the event that the confiscation order is not satisfied.

Denmark – company self reports to Danish Business Authority for possible sanctions breaches

Danish company FLSmidth & Co A/S has issued a press release stating that it has self-reported the outcome of an internal investigation to both OFAC and the Danish Business Authority and will cooperate with the authorities.

The press release states that the internal investigation ” identified information indicating that certain pre-contract tender materials have been provided to persons in the Russian Federation in connection with a limited number of potential projects in Kazakhstan”.

The press release adds that as a result of the internal investigation the company is “in the process of reviewing and enhancing its compliance programme and risk management measures as well as other mitigating action”.

Sweden – Chinese captain of Syrian-flagged ship the Jin Hui arrested and ship detained

On Sunday Sweden’s Prosecutors announced the arrest of a Chinese national who was the captain of the Syrian-flagged vessel suspected of belonging to the Russian shadow fleet, the Jin Hui.

The particular offences forming the basis for the captain’s arrest are the use of false documents and suspected violations of the Maritime Act in relation to seaworthiness.

The vessel is reported to have been in Swedish territorial waters at the time it was detained and is now anchored off Trelleborg.

Sweden – Prosecutors seize cargo vessel and seek confiscation

Further to our earlier post regarding the boarding and capture of a cargo vessel, the Caffa, the Swedish Prosecutor’s Office has announced that the vessel has now been formally seized the vessel “in order to obtain a judicial review of whether the vessel can be handed over to the state”.

Press headlines that the vessel has already been fully confiscated appear to be overstating the current position.

The press release adds that the investigation involves a request for mutual legal assistance from another state, but that state is not named. The vessel is suspected of having been carrying stolen Ukrainian grain and to have been sailing under false flag documentation.

Germany – publication of the latest 6-monthly sanctions enforcement update

The German authorities have published the third instalment of their 6-monthly updates on their current enforcement actions.

The report highlights:

  1. The conviction on 2 March 2026 of two individuals relating to the export of 111 luxury cars to Russia, with €20m confiscated, and jail sentences of 6 years and 2 years (the latter suspended). See our previous post.
  2. Raids conducted in November 2025 and the ongoing investigation into the suspected export of machine tool to Russia value at €1.7m. The report confirms that the investigation by the Stuttgart Public Prosecutor’s Office and the Stuttgart Customs Investigation Office remains ongoing. See our previous post.
  3. An investigation into five suspects for the organized circumvention of sanctions against Russia. A company is alleged to have exported technical equipment and accessories worth c. €689,000 to a company in Russia via third countries. The investigation started in February 2025 and is being conducted by the Essen customs investigation office, is ongoing. See our previous post.
  4. The prosecution of a 41-year old suspected of exporting 236 cars to Russia valued at approximately €18.86m. See our previous post.
  5. The arrest of five suspects on 2 February suspected of 16,000 illegal deliveries to 24 listed Russian arms companies of good worth at least €30m. The prosecution was supported by the Federal Intelligence Service (the BND). See our previous post.
  6. On 27 March raids conducted on 14 premises in the Rhine-Main region against two companies suspected of exporting machine parts and chemicals to Russia. A third company is said to have been involved in the alleged use of a transport and logistics companies to try and circumvent the EU’s sanctions. See our previous post.
  7. The ongoing investigation into a member of the Saxon state parliament for allegedly falsifying the export declaration in relation to a telescopic handler rather than stating the correct destination of Belarus. Searches were conducted at residential and business premises. See our earlier post.

The update also reports on a decision of the CJEU from 5 February 2026 upholding the seizure by German customs of a Mercedes car purchased in Russia and imported to Germany. The CJEU held that the single specific import did not need to “generate significant revenue for the Russian state”, so long as the general category of goods did.

Further cases noted previously in the blog over the last few months, but not included in the report are:

  • an investigation from February 2026 in relation to the import of goods valued at over €4m from Russia;
  • an investigation made public in January 2026 into the use of RussPost to export goods to Russia;
  • reporting from January 2026 into a mutual legal assistance request made to Ukraine as part of an investigation into the suspected export of drone parts to Russia;
  • the arrest in January 2026 of two people on suspicion of making available funds and economic resources to the Donetsk and Luhansk People’s Republics;
  • an investigation made public in December 2025 by the Munich Prosecutor’s Office into alleged export of 50 luxury cars valued at over €10m; and
  • raids in November 2025 in relation to the suspected export of 346 cars to Russia.

Estonia – individual charged and settlement with a related company as part of Russian sanctions investigation

Further to our earlier post, the Estonian Public Prosecutor has charged Oleg Bessedin on suspicion of:

“transmitting sanctioned Russian TV programs and content via TV and social media channels controlled by him in Estonia and making the sanctioned content available to other channels as well”.

He is also charged with non-violent offences against the independence, sovereignty and territorial integrity of Estonia.

As part of the same investigation, the Prosecutor’s Office reached a settlement with an unnamed legal entity as part of which that entity made a charitable donation of €4000 to a Ukrainian support charity.

Latvia – company liquidated and director fined, and second company fined for Russian sanctions breaches

It is being reported that the Latvian authorities have entered into settlement agreements with two companies and a director of one of the companies in relation to resolving prosecutions for breaches of the EU’s Russian sanctions.

The director of the company to be liquidated was fined €10,140 and the second company was fined €17,940.

The first company (unnamed) had accepted an order to ship to Russia Buchholz relays and control relays designed to protect transformers, with a total value of €161,352.

The exporter approached a customs broker (the second unnamed company) to assist with the shipments to Russia. The broker was not told, and nor did it make enquiries, about the prohibited status of the goods.

The shipment did not proceed, but was stopped after an export declaration was made at the Riga Free Port.

Poland – company exporting luxury cars to Russia fined c. €4.7m

Poland’s National Tax Administration has fined a company based in Małopolska and run by Belarusian citizens PLN 20,000,000 – or approximately €4,726,000. The fine is administrative, and was the maximum allowable fine.

The company had exported over 100 luxury cars to Russia via Lithuania and Belarus in breach of EU sanctions.

The total value of the cars is said to have been PLN 49m. The press release states that “The evidence gathered indicates that the company’s managers acted knowingly and deliberately participated in the circumvention of sanctions”.

The press release does not mention if proceedings are also being brought against the individuals involved or if the company will be subject to a confiscation of its profits.

France – owner of seized tanker admits no evidence of flag status and pays fine to secure release

Further to our earlier post, the owner of the “shadow fleet” vessel the MV Deyna, agreed in a Marseilles Court on Wednesday to pay an undisclosed fine for the release of the vessel.

The owner admitted that it had no evidence to support the vessel’s alleged Mozambique flag status.

Upon payment the vessel was released and is now reported to have left French waters.

© 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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