Trade Sanctions – Page 12 – European Sanctions Enforcement

February 21, 2024 by Mark Handley

Switzerland – updated enforcement statistics including 9 fines

Sanctions enforcement statistics for Switzerland’s SECO have been reported today. These are an update on those previously published in May last year.

- 230 reports to SECO of potential sanctions breaches:
- 47 proceedings commenced, of which:
  - 18 cases remain active;
  - 9 fines imposed; and
  - 20 cases discontinued.

SECO also stated that new cases are being added all the time, and that most relate to trade sanctions.

No information was published as to the level of the fines imposed (other than “varying severity”), or the identities of those fined or being investigated or prosecuted.

February 19, 2024 by Mark Handley

Finland – 700 Russian trade sanctions investigations of which 70 are large and complex

In September 2023, the Finnish Customs authorities announced they had 600 ongoing criminal investigations of which 60 were “aggravated”.

As reported in Wirtschaft Woche Sari Knaapi , the Chief Economic Crimes Investigator at Finnish Customs has now given details of the current figures, stating that there are now 700 ongoing investigations, with around 70 that are described as “large, complex cases”.

February 9, 2024March 19, 2024 by Mark Handley

Latvia – further sanctions enforcement statistics including seven convictions

The Latvian authorities have provided a further update to their enforcement efforts. As reported:

- 281 sanctions-related suspicious activity reports in 2022
- 510 sanctions-related suspicious activity reports in 2023
- 310 criminal cases commenced
- 22 prosecutions in which the trial has started
- 7 convictions to date.

Of the convictions, all involved guilty pleas and all involved Latvian nationals. The highest penalty related to the export of a luxury car, and the fine was €170,000.

The conduct prosecuted included in relation to the sale of a professional footballer to a club owned by a company designated under Belarus sanctions, and the provision of content to the Russian Federal News Agency.

UPDATE: It has now (18 March 2024) been reported that the fine imposed in relation to providing economic resources to the Russian news agency in the form of employment services, was €15,500.

February 2, 2024 by Mark Handley

Moldova – first known investigation into Russian sanctions breach

It has been reported that the Moldovan authorities are investigating allegations that three Moldovan companies have sold $15m in aircraft parts to Russian airlines.

Moldova, although not a part of the EU, has adopted its own sanctions against Russia.

The three companies are Airrock Solutions, Aerostage Services and Maxjet Service. It is alleged the companies acted as intermediaries, purchasing the parts from suppliers and then on-selling.

It is being reported that the companies deny knowing that the parts were being delivered to Russia and that they each thought the parts were going to other CIS countries.

The confirmation of an investigation is reported to have come from the office of the President of Moldova.

January 25, 2024 by Mark Handley

Latvia – announcement of 258 ongoing criminal prosecutions

In an earlier post we reported that the Latvian authorities had 14 ongoing criminal prosecutions.

This morning, Raimonds Zukuls of the Latvian State Revenue Service has given an interview announcing that 114 criminal cases were opened during 2022 and a further 144 cases were opened during 2023.

These cases all concern the EU’s Russian and Belarusian sanctions. It was also said that most cases relate to electrical goods, car parts, luxury goods, timber products, fuel, fodder and metal products.

It was also stated that over 5,000 imports/exports had been stopped by the State Revenue Service.

January 23, 2024January 25, 2024 by Mark Handley

Netherlands – three arrested on suspicion of circumventing Russian sanctions

The Dutch FIOD has today announced three arrests as part of an ongoing criminal investigation into suspected exports in circumvention of the EU’s trade sanctions against Russia.

The individuals are two men from Diemen and a woman from The Hague. The men were both directors of a company founded in 2017, and the arrested woman was an employee.

UPDATE: it is now being reported that the Dutch company involved is ETW-Tekhnologiya and that the company’s founder, Mikhail Volovik, is being sought but has not yet been arrested

The goods are described as technological and laboratory goods capable of military use – i.e. dual-use goods.

Searches and witness interviews have taken place in the Netherlands, Germany, Latvia, Lithuania and Canada.

January 22, 2024January 22, 2024 by Mark Handley

UK reports Russia to UN North Korean sanctions committee

It has been reported today that the UK has provided the UN Committee responsible for oversight of the UN’s sanctions against North Korea with a dossier of evidence said to establish breaches of those sanctions by Russian shipping.

The Committee has the power to designate vessels which it finds were complicit in breaching the existing sanctions.

January 18, 2024 by Mark Handley

Latvia – importer referred to criminal authorities

It has been reported today that the Latvian National Regional Development Agency (the “VRAA”) has referred the Latvian company LLC Lanekss to the criminal authorities for investigation.

The allegations arise out of LLC Lanekss being a seller of products on Latvia’s electronic public procurement sale platform – the EIS.

The Latvian state broadcaster (LTV) purchased tea through the EIS which when delivered was stated to have been manufactured in Russia.

As article 5k of EU regulation 833/2014 prohibits the award of a contract within the scope of the EU’s Public Procurement legislation to a Russian company or individual, or a company more than 50% owned by a Russian company or individual, the VRAA has referred the case to law enforcement for investigation.

January 16, 2024January 16, 2024 by Mark Handley

Finland – five charged with EU Russian sanctions offences

It has been reported that the Finnish authorities have charged five individuals with sanctions offences.

The allegations relate to the export of drones to Russian in breach of EU sanctions.

The first defendant is Gabriel Temini who is the CEO of the Finnish companies Luminor and Siberica.

Three employees of Siberica have also been charged as well as an employee of a freight forwarding company.

The charges are denied.

Trial is scheduled to commence on 26 January 2024.

December 27, 2023January 11, 2024 by Mark Handley

Romania – company fined and €2.9 million profits confiscated

An Advocate-General’s opinion in Case C-351/22 before the Court of Justice has revealed details of a not-previously publicised enforcement action from 2020 in Romania, by which the company Neves 77 Solutions SRL was administratively fined approximately €6,000 and had gross profits of €2.9 million confiscated.

The company had brokered a transaction whereby radio sets manufactured in Russia were sold by a Ukrainian company to an Indian company.

The question which came to be addressed by the Advocate-General was whether the confiscation of gross profits was compatible with fundamental principles of European law including whether it was a proportionate abrogation of the right to property. The Advocate-General’s opinion is that such confiscations are not a breach of European law.