Estonia – details of eleven Russian sanctions convictions

Further to the earlier post about Estonia having obtained 8 criminal convictions during 2024, we can publish details of the criminal convictions for breaches of the EU’s Russian sanctions that have been published on Estonia’s searchable gazette of published judgments.

As well as one conviction obtained in 2022, below we are publishing summaries of seven of the convictions from 2024 and three from 2025 (not including the conviction made public on 16 April 2025) as well as machine translations of the respective judgments.

The sentences range from fairly small monetary fines up to custodial sentences of 5 years in jail.

  1. Judgment of 10 October 2022 – Petr Rafalovich (a Belarus national) was convicted and given a two month sentence following which he was to be deported to Belarus and given a five-year ban from re-entering Estonia. He was also ordered to pay a penalty and costs of €1,250.40.

The offence was the attempt to export a 3D printer and an electromagnetic positioner. Mr Rafalovich was carrying false papers indicating the goods were destined for an Armenian company, as well as other papers indicating the true recipient to be a Russian company.

2. Judgment of 5 February 2024 – Victor Manilo was convicted and ordered to pay €2,680 as a fine.

The offence was the attempted export of €14,000 in physical currency to Russia.

3. Judgment of 14 February 2024 – Galina Sergejenkova was convicted and ordered to pay €3,960, such payment suspended for a probationary period of 18 months. A separate payment of costs and a penalty of €1,434.96 were to be paid straightaway.

The offences were two attempts to transport physical currency (of €900 and €1,000 respectively).

4. Judgment of 27 February 2024 – Evgeniy Kozlovtsev was convicted and given an eight month sentence suspended for a probationary period of 18 months. He was also ordered to pay a penalty and costs of €1,430.

The offence was the attempted export to Russia of two bottles of wine greater than the €300 luxury threshold. It was the man’s second attempt at such exports.

5. Judgment of 8 March 2024 – Aleksei Bond was convicted and given a five month prison sentence suspended for a probationary period of 18 months. He was also ordered to pay a penalty and costs of €1,555.

The offence was the attempted export of a luxury watch valued at €13,900 to Russia.

6. Judgment of 27 March 2024 – Lev Pylkin was convicted and ordered to pay a penalty of €1,190, as well as confiscation of the cash he attempted to export to Russia.

The offence was the attempted export of €2,560 in physical currency across the border to Russia. He had previously attempted to export cash at which time the details of the offence had been explained. The judgment is the dismissal of an appeal against the conviction and sentence.

7. Judgment of 17 October 2024 – Ruslan Sibilev was convicted and ordered to pay a fine of €79,557.50 as well as confiscation of a large number of rifle scopes, binoculars and other equipment.

The offences were committed through the acquisition of a range of sanctioned goods from a Portuguese company and an Austrian company, with Sibilev acting to coordinate further transport for the export of the goods to Russia. The orders were placed between May 2022 and April 2023. The total value of the goods ordered was nearly €1 million.

8. Judgment of 16 December 2024 – Oleg Osipov was convicted and sentenced to 8 months in prison suspended for a probationary period of 18 months. He was also ordered to pay €13,230, including 100% of the fee earned as part of the sanctioned transactions.

The offences were committed through Osipov providing a brokering service for the export of luxury goods to buyers in Russia between May and July 2023. The goods included electrical goods, phones, alcohol, navigation systems and various automotive parts. Osipov contracted with others to deliver the goods and took a brokering fee for arranging the transactions.

9. Judgment of 14 February 2025 – Demyan Belyakov was convicted and sentenced to 5 years in jail and ordered to pay €8,231 in costs and other penalties. In addition a large volume of goods were confiscated.

The offences were committed through the actual and attempted export to Russia of hundreds of silencers and firearm flash suppressors between February and June 2024.

10. Judgment of 20 February 2025 – Andrei Klychkov was convicted and sentenced to serve two months in prison plus a further period of 2 years and 10 months suspended for a probationary period of 4 years. €5,000 was also confiscated and he was ordered to pay costs of €2,581.

The offences were committed by the attempted export of parts for firearms, to Russia.

11. Judgment of 21 March 2025 – Aleksandr Ivantsov was convicted and sentenced to 4 years, 11 months and 27 days (after deducting 3 days of pre-trial detention) suspended for a probationary period of 5 years and other conditions including a requirement for prior permission to be away from his house for more than 15 days, and permission to leave Estonia. He was also ordered to pay €2,215 and had 70,550 rubles, and other goods, confiscated.

The offence was committed by the attempted export of six pairs of night-vision binoculars.

This case is related to that above for Ruslan Sibilev with Mr Ivantsov being one of the people used to try and physically carry the goods across the border into Russia.

Netherlands – timber confiscations from companies already under investigation for alleged sanctions violations

As reported in our post from June 2024, at that time the Dutch FIOD conducted raids and arrested two individuals suspected of importing Russian-origin timber in breach of the EU’s sanctions.

FIOD has now announced a further round of seizures from the same companies. The allegation is that the companies have continued to trade in Russian timber during the pendency of the ongoing investigations into their activities.

Finland – investigation into suspected nuclear-related breach of Russian sanctions

Finland’s Customs have issued a press release making public an investigation into the suspected export of technical documents from a nuclear power plant construction project to Russia.

The unnamed manging director of the company responsible for the construction project is identified as the person suspected of the offence.

The press release notes that the investigation is coming to an end and that, as yet, no decision on charging the individual has been made.

Estonia – seizure of Russian shadow fleet oil tanker

On Friday the Estonian Navy has seized an oil tanker (the Kiwala) forming part of the so-called “shadow fleet”. The Kiwala is designated by the EU.

During a routine inspection of the vessel’s documentation, it was determined that the vessel was not validly flagged in any country and did not have valid insurance.

The vessel has been detained pending rectification of the documentation and other safety issues.

Norway – investigation into shadow fleet “insurance” provider

It has been reported that police in Oslo are investigating a company called Romarine AS, as well as four individuals (two Norwegians, a Russian and a Bulgarian) relating to the insurance services provided to Russian shadow fleet vessels, and vessels sanctioned by the EU.

The allegations include the provision of faked insurance documentation purporting to show that the vessels had valid insurance, and the provision of unauthorised insurance services.

The Oslo Police were referred the case by the Norwegian Financial Supervisory Authority which has issued an order for Romarine to cease operations.

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”.

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.

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.

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.

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.

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The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

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