Finland – two individuals charged with sanctioned export offences

Further to our earlier post, it is now being reported that the Finnish authorities have charged the two remaining defendants (the first having plead guilty) on suspicion of exports to Russia of dual-use drones, laptops, computer processors, smartphones and laser rangefinders in breach of the EU’s sanctions.

The value of the exports is said to have been around €140,000, with the exports said to have taken place between 2022 and 2024.

Germany – raids and arrests as part of investigation into exports of equipment to Russia

German Customs has issued a press release relating to an ongoing investigation against five defendants. On 29 November three properties were raids in Oelde, and two individuals were arrested.

The investigation by the Essen Customs office, relates to the export since January 2023 of technical equipment and accessories, such as pumps, valves, filters to a company in Russia.

It is suspected that 53 shipments may have taken place via third countries.

The investigation has also frozen assets valued at €689,000.

Estonia – four criminal convictions for Russian sanctions offences

The website containing published judgments from the Estonian courts has published a number of judgments relating to convictions for sanctions offences.

1. Conviction of Adilov Mubariz on 23 July 2025

      Decision: https://www.riigiteataja.ee/kohtulahendid/detailid.html?id=413740161

      This individual was convicted of importing a few hundred Russian cigarettes into Estonia in breach of Article 3(i)(1) of EU Regulation 833/2014. This was a second offence.

      The man was given a 3-month jail term, suspended for a 12-month probation period, and ordered to pay €798.42.

      2. Conviction of Alus Grupp OÜ and Taras Potapov on 18 September 2025

      Decision: https://www.riigiteataja.ee/kohtulahendid/detailid.html?id=419399125

      Mr Popatov was convicted of aiding and abetting the provision of a service related to a prohibited strategic good, namely resonance testing machines used in the aviation and aerospace industries. These are dual use goods

      The company Alus Grupp is a freight forwarder and Mr Popatov was one of its directors.

      Another Estonian company and its director purchased the equipment from a supplier in Switzerland and sold them to Russian customers. The invoices showed that the intended ultimate customer was a Russian company. Alus Grupp and its director, being aware of the ultimate customer, on multiple occasions transported the goods to Kazakhstan. On other occasions an intermediary based in the UAE was inserted.

      Mr Popatov was convicted. At the time of his conviction he had already served 5 months in jail. Pursuant to an agreement with the prosecution, the remainder of his 5-year sentence was suspended subject to a 5-year probation period. He was also ordered to pay a penalty of €2,215.

      The company was also convicted and given a fine of €100,000 with a further €200,000 suspended for a 5-year probation period.

      The judgment gives a detailed account of the exporting arrangements. It appears that other prosecutions of the actual exporting parties are ongoing.

      3. Conviction of Anna Shmeljova on 14 October 2025

      Decision: https://www.riigiteataja.ee/kohtulahendid/detailid.html?id=422536761

      Ms Shmeljova was convicted of multiple offences including exporting luxury goods to Russia, namely clothing and hockey skates, and importing cigarettes.

      She was ordered to pay €2,215, and given a five-month jail sentence suspended for a one year probation period.

      4. Conviction of Marine Technics Baltia OÜ and Daniil Haitin on 5 November 2025

      Decision: https://www.riigiteataja.ee/kohtulahendid/detailid.html?id=424933869

      Mr Haitin was convicted of four offences and sentenced to 4 years and eleven months in jail. This sentence was suspended for a 5 year probation period. He was ordered to pay €2,215.

      The company Marine Technics was convicted of two offences and ordered to pay €160,000, as well as €13,251.65.

      The offences related to exports of gas generators, alternators, propulsion systems, thermal cameras and other equipment to Russia, including to military end-users such as Kalashnikov Concern, and the Russian Ministry of Defence.

      False end-user certificates were prepared showing purported customers in Turkey.

      The offending had taken place between 2017 and 2019.

      The judgment notes that the court had prevented the merger or winding up of Marine Technics Baltia OÜ for the duration of the investigation in order to be able to secure a conviction and penalty.

      The judgment gives a detailed account of the exporting arrangements.

      Finland – regulator’s audit findings on Nordea Bank’s sanctions compliance

      Finland’s Financial Supervisory Authority has published the results of an “audit” on Nordea Bank in relation to the bank’s compliance with the asset freeze and export prohibition aspects of the EU’s Russian sanctions.

      The result of the audit was a finding of a “very significant lack of information obtained and retained by the bank”, with a lack of updating on the information that was obtained. In addition, “shortcomings of great significance” were found in relation to customer due diligence, and a lack of adequate assessment of the risk of sanctions circumvention including payments that involved “a high risk country from the perspective of sanctions evasion”.

      The announcement from the FIN-FSA does not indicate whether any further regulatory action will be taken.

      My thanks to Louis Vargas of the Network for Financial Crime Prevention for informing on this published audit.

      Netherlands – trial commenced of shipbuilder for sanctioned exports to Russia

      Further to our earlier post, the prosecution trial of Damen Shipping has commenced in the Netherlands.

      The company has denied the allegations, which include that it falsified customs declarations to enable the export of 14 deck cranes to Russia during 2022 in breach of the EU’s sanctions.

      Senior management have also been charged with sanctions offences.

      The trial includes charges of bribery against Damen.

      Germany – raids in relation to export of hundreds of luxury cars to Russia

      It is being reported that seven residential and commercial premises in the Steinfurt area were raided on 20 November by Customs officers from Essen, Münster and Osnabrück.

      The raids relate to allegations that three individuals (aged 57, 32 and 27) were involved in the export of 346 luxury cars to Russia via third countries in breach of the EU’s sanctions.

      The exports are said to have taken place between 2022 and 2024 and have totalled approximately €20m in value.

      The report adds that assets (including real estate, cars and bank accounts) valued at €20m have been seized as part of the investigation.

      Sweden – Swedish Customs sanctions enforcement

      The Swedish Police have issued a report on sanctions compliance in the country, concluding that trade flows to countries neighbouring Russia suggests Swedish involvement in the circumvention of the EU’s sanctions.

      In relation to the work of Swedish customs, the report noted that in 2023 more than 200 export shipments were stopped, and that 3,000 export declarations in 2024 were “subject to special review measures”.

      The press release to the report notes that “a handful of preliminary investigations [are] underway regarding sanctions violations at the Police Authority and at Swedish Customs”.

      The report also highlights an earlier 2024 report by the Swedish Financial Supervisory Authority on the outcome of its review of the sanctions screening processes and methodologies of 19 banks operating in Sweden. The report noted that none of the banks assessed had good enough automatic screening in place, but that the larger banks were better at screening than the small and medium sized banks.

      Germany – arrest and raids related to machinery exports to Russia

      German Customs has issued a press release reporting that the Customs Investigation Office and Public Prosecutor’s Office in Stuttgart have overseen raids on private and company premises relating to alleged machinery exports to Russia in breach of the EU’s sanctions.

      Raids and searches were conducted on 10, 14 and 18 November and a 55-year old man has been arrested.

      It is alleged that 5 machine tools were exported to Russia via third countries between October 2023 and December 2024. The value of the machinery is stated to have been €1.7m.

      As well as raiding the exporting company, raids were also conducted on the premises of a freight forwarding company in Duisburg.

      Germany – sanctions trial begins of individuals suspected of exporting €28m in luxury cars

      The trial has commenced in Berlin of Evgeniya P., Wladimir K. and Ekaterina M. Only Evgeniya P. is before the court, the others are being tried in absentia.

      The three are alleged to have exported 257 luxury cars to Russia in breach of the EU’s sanctions with a value of €28.2m.

      The exports are reported to have been completed via Belarus, Kyrgyzstan, Kazakhstan or Turkey.

      Latvia – company and individual convicted for organizing tour groups to Crimea

      Latvia’s FIU has announced the successful appeal of an earlier acquittal resulting in the conviction of an individual and company for providing services related to the tourism sector in Crimea – i.e. organizing tourist trips to Crimea.

      The case remains subject to further appeal.

      The company was fined €10,500 and the individual sentenced to 100 hours of community service.

      © 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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