Finland – 40 further EU Russian trade sanctions investigations commenced

At the time of our earlier post in February the Finnish authorities were stating that they had 700 ongoing investigations into alleged breaches of the EU’s trade sanctions against Russia.

It is now being reported that they have “over 740” preliminary investigations into such breaches which suggests that a further 40 investigations have commenced in the interim.

No further details have been published on these new investigations.

Netherlands – company convicted of sanctions breaches ordered to be liquidated

As per our earlier post, in November last year the Public Prosecution Service in the Netherlands applied to wind up a company convicted of breaching the EU’s sanctions by unlawfully exporting goods to Russia.

Yesterday, the District Court of Gelderland issued its order and judgment in the case. The court granted the application to wind up the company and appointed a liquidator to oversee the process.

The court noted that the company had ceased to trade and that its director and shareholder (also convicted) had fled the Netherlands for Russia.

The court did not grant the Prosecution’s application to immediately turn over all funds in the company’s bank accounts as the proceeds of crime. Rather the court has left the question of what funds are the proceeds of crime “to the liquidator to make an independent assessment”.

The case is an illustration of the powers available to courts post-conviction.

Poland – sanctions investigation commenced into state-controlled oil trading company

After first being reported by Polish radio station Radio Zet, it is now being reported in the press that the Polish Special Services has commenced an investigation into whether the Swiss oil trading subsidiary of a state-controlled oil company has breached the EU’s Russian sanctions in relation to oil.

The Polish parent company is Orlen, which is 49% owned by the Polish state, and the Swiss subsidiary is Orlen Trading Switzerland.

It is alleged that the Swiss subsidiary was incorporated in Switzerland in late 2022 ahead of the relevant changes to EU sanctions which came into effect in early 2023 as a means of continuing to purchase and trade in oil of Russian origin.

The companies are reported as having denied the allegations.

Latvia – investigation into bunkering vessel refueling Russian “shadow fleet”

A vessel owned by a Latvian company is providing bunkering (i.e. refueling) services to the Russian “shadow fleet” in the Baltic sea off the coast of Gotland in Sweden.

A spokesman for the Latvian Foreign Ministry has stated that an investigation is now underway to see if the Latvian company is breaching or circumventing EU sanctions, in particular whether the fuel being supplied is of Russian origin.

The Latvian company, Fastbunkering, denies breaching sanctions.

It is noteworthy that just two days ago the Swedish authorities were reported as having closed an investigation into these same possible breaches of sanctions.

A Swedish prosecutor was reported as having stated: “I have made the assessment that it is not worth requesting legal aid from Latvia because it is not expected to lead to a higher penalty than a fine“.

Cyprus – more than 40 ongoing Russian sanctions investigations and first indictments expected soon

The Cypriot authorities have more than 40 ongoing criminal investigations related to alleged breaches of the EU’s Russian sanctions.

It is being reported that yesterday the current status of “all open cases exceeding 40 were reviewed” by the Law Office and the state’s Attorney General, with the Office for Economic Crime Investigation.

It is also being reported that for the completed investigations “indictments will be prepared to initiate criminal prosecutions in court”.

Lithuania – Customs Department launches investigation into exports to Russia

Following press reporting into allegations that the Viciūnai Group of companies were exporting sanctioned goods to Russia, it is now being reported that the Lithuanian Customs Department has commenced a pre-trial investigation.

The allegations include that dual use and “battlefield” goods were being exported to a factory in Kaliningrad operated by a related company.

It is reported that the company has confirmed the fact of the exports, but claims that it was not aware that the goods in question (which includes ball bearings, semi-conductors, electrical components and other goods) were subject to sanctions.

 

Germany – Ministry of Economic Affairs calls for investigation into alleged sanctions breaches relating to Mariupol reconstruction

The German Ministry of Economic Affairs and Climate Change is being quoted in the press as having called for an investigation by the relevant authorities into allegations that two German companies may be breaching the EU’s sanctions by providing material for the rebuilding of the occupied city of Mariupol.

The companies, Knauf and WKB Systems GmbH have both issued statements saying they comply with relevant sanctions.

The call for an investigation follows reports of the supply of construction material first published in Monitor.

Ireland – investigation launched into alleged breaches of EU and UN Libyan sanctions

The Irish Department of Enterprise, Trade and Employment has launched an investigation into alleged breaches of both UN and EU sanctions against Libya first reported in the Irish Times.

It is alleged that former members of the Irish Defence Forces provided military training and material to forces of Khalifa Haftar’s Libyan National Army in breach of relevant arms embargoes.

It is alleged that the initial contract was entered into by an Irish company co-owned by Danny Cluskey, Darren Kelly and Nigel McCormack, and that the contract was then switched to a Dubai-based company (SOF Training).

 

Germany – five charged in relation to the export of Siemens’ gas turbines to Crimea

It is being reported that the Hamburg Public Prosecutor’s Office (which does not publish press releases online) has charged five individuals on suspicion of exporting gas turbines to Crimea in breach of EU sanctions.

The gas turbines were manufactured by Siemens.

Of the five individuals, who have been under investigation since at least 2021 (see our earlier post), one remains an employee of Siemens. Four are German nationals and one is Swiss.

It is alleged that they were aware that the gas turbines being exported to Russia (then not prohibited) were destined for export and installation in Crimea in breach of the EU’s Crimea-specific sanctions.

Latvia – arrest on suspicion of breaching US sanctions

The US Department of Justice has issued a press release confirming that the Latvian authorities have arrested a 55-year old, Oleg Chistyakov.

He has been charged with multiple counts of breaching US sanctions and other offences as part of an alleged wider conspiracy with two other also-charged individuals to supply avionics materials to Russia in breach of US sanctions.

The man was arrested near Riga on 19 March pending proceedings for extradition to the United States.

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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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