Lithuania – raids and 10 arrested for suspected prohibited exports to Russia

Lithuania’s State Security Department has issued a press release detailing raids and arrests carried out on 14 January of this year involving ten suspects.

The investigation was said to have been a collaborative effort also involving Estonia and Latvia.

The principal suspect is a Russian national who is alleged to have orchestrated the supply of high-tech equipment manufactured in Lithuania to Russian customers related to the Russian defence and security industry. He remains in custody. The other suspects have been released subject to conditions.

A pre-trial investigation has been commenced by the Vilnius Regional Prosecutor’s Office in relation to the suspects.

United Kingdom – HMRC unaware of how many sanctions investigations it is currently conducting

Sky News in the UK has made a Freedom of Information Request to the UK’s primary trade sanctions enforcement body, His Majesty’s Revenue and Customs (HMRC), asking for the “number of cases you are currently investigating”.

See the Sky News piece here (including some comments from Mark Handley of this blog).

HMRC has responded (available here and with thanks to Sky News for providing a copy).

It has said that “the number of current investigations … is not centrally recorded. To determine how many investigations are within scope of your request would require a manual search of a significant number of records, held by different business areas“.

Sky News also asked about the identities of the entities or individuals which have received the six compound penalties for breaches of the UK’s Russian sanctions.

In line with HMRC policy this information was not disclosed because “HMRC do not consider that disclosing the company name would drive compliance, promote voluntary disclosure or be proportionate“.

While this has long been HMRC’s policy, the stance of OFSI and the new Office of Trade Sanctions Implementation is that they will each name the companies subjected to fines.

Germany and Finland: sanctions investigations re seized “shadow fleet” vessels

It is being reported that the Panama-flagged vessel, the Eventin which has been seized and detained by Germany after it lost power on 10 January, is currently the subject of a sanctions investigation by the General Customs Inspection Office.

The investigation relates to the cargo of 100,000 tons of oil on board.

In a similar story, it is being reported that the Finnish authorities have concluded an investigation into possible sanctions breaches in relation to the Eagle S, the vessel suspected of being involved in disruption to undersea cables.

The Finnish authorities investigated the cargo of unleaded petrol and diesel on board, but determined that as the vessel only entered Finland’s territorial waters at the request of the Finnish authorities it cannot be said to have intentionally violated the prohibitions on the import of Russian oil products.

United Kingdom – National Crime Agency gives update on sanctions enforcement

As first reported by the BBC, the National Crime Agency has written to the Chair of the Treasury Committee of the House of Commons to respond to a series of questions about the NCAs sanctions enforcement efforts to date.

The letter confirms that there have been no convictions obtained under Russian sanctions, or indeed any sanctions regime since the coming into force of the Sanctions and Anti-Money Laundering Act in January 2021.

The NCA also stated that “a very small proportion” of its workload is sanctions-related, but it would not disclose how many cases had been referred to it by OFSI or any other body, or how many active investigations followed from the 5,600 sanctions-related suspicious activity reports it received in the year 2022-2023.

The letter also stated:

the NCA’s Combatting Kleptocracy Cell (CKC) has delivered over 150 disruptions, which include: asset freezes and forfeiture, taking action against key enablers, and supporting international partners” and then gave a number of specific examples including the successful forfeiture of £780,000 obtained in July 2024.

Another example given was “The arrest of enablers in the regulated sector who support the transactions of corrupt elites“, although no further detail was provided.

Finland – sanctions enforcement statistics: over 900 investigations, hundreds of fines and dozens of convictions

Press reporting in Finland has provided an update on Finland’s sanctions enforcement.

The update provides:

  • over 900 preliminary investigations commenced by Finnish Customs:
    • 13 started between 2018 and 2021;
    • 306 started in 2022;
    • 492 started in 2023; and
    • 83 started in 2024 (January to September, with an uncertain number since then)
  • “More than half” involved minor regulatory offences and have been resolved by monetary fines without recourse to the court system. These cases are further described as: “The fine cases mainly concern private individuals who have exported small quantities of banned goods across the border. Private individuals have exported, for example, luxury goods, not equipment needed by the military“.
  • “Dozens” of convictions and fines imposed by the courts for more serious offences. These are described as: “characterized by planning, systematicity and the pursuit of significant financial gain. Most often, they involve equipment needed on the front line. … The perpetrators in such cases are typically small or medium-sized export or logistics companies“.

The report provides no further details on the precise number of fines, the amount of fines, or other sentencing involved.

A separate report notes that the Finnish Navy has established a controlled area in the Gulf of Finland where Russian-linked vessels are inspected. This de facto maritime detention zone is encircled by Finnish naval forces and that currently 20 Russian “shadow fleet” vessels are “under scrutiny, with several facing potential long-term detention“.

Finland – sanctions investigation closed into returned Russian art

In April 2022 Finnish Customs seized over 200 pieces of art being shipped back to Russian museums such as the State Hermitage Museum and the Tretyakov Gallery.

It is now being reported that at that time an investigation was commenced by Finnish Customs working with the Finnish Foreign Ministry as to whether permitting the onward transit of the objects and artefacts, or the shipments themselves, would amount to breaching EU sanctions.

The artefacts were later allowed to travel on to Russia while the investigation continued.

As of 24 December 2024, it is now being reported (in the linked article above) that the investigation has concluded with no further action to be taken.

Latvia – more than 100 criminal cases for sanctions breaches commenced during 2024

It has been reported that the Latvian authorities commenced 100 criminal cases for suspected sanctions violations during 2024.

In late October 2024 the figure was reported as 94, meaning that the final weeks of the year continued to see new criminal cases started.

The cases appear to be predominantly related to breaches of trade sanctions and the reporting states that the prohibited products included “engines, steel products and optical devices”.

United Kingdom – three penalties imposed by HMRC for breaches of Russian trade sanctions

On 4 November 2024, HMRC published a Notice to Exporters regarding a compound penalty of £58,426.45 imposed for breaches of Russian trade sanctions.

The Notice included the line:

Since February 2022, HMRC has issued six compound settlements against UK companies that have breached the Russia sanctions regulations for a total of £1,363,129, including one in August 2023 for £1 million“.

This struck a chord because, as captured in this blog, only three compound penalties had been publicly imposed by HMRC for breaching Russian sanctions. So a Freedom of Information request was made about the other three.

The response is here.

The response discloses details of three compound penalties (totalling c. £237,000) from August and September 2022 and April 2023. These had each been previously published, but had not previously been described as relating to Russian sanctions.

  • August 2022 – £1,000.00 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
  • September 2022 – £19,689.20 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
  • April 2023 – £217,012.50 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.

It is unclear why these penalties were not previously described as relating to breaches of Russian sanctions.

The FOIA request also asked for the names of the individuals or companies which were the subject of the penalties; whether any had self-reported; and what (if any) confiscation of the proceeds of crime was applied. These questions were not answered.

Estonia – police and border guards conduct over 240 inspections of Russian “shadow fleet” vessels

It has been reported that Estonia’s police and border guards have between them conducted over 240 inspections of vessels in waters of Estonia’s economic zone in the last 6 months. Estonia adopted the policy of conducting inspections in June of this year.

The vessels are said to belong to Russia’s so-called “shadow fleet” and the inspections relate to verifying compliance with requirements such as valid insurance.

© 2009-2025 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.

Proudly powered by WordPress