**Case: Sanctions Circumvention Leading to Conviction**
As Russia’s demand for luxury goods remains high, we reflect on a case from 2022-2023 where the actions of the FIU – from freezing funds to disseminating intelligence to a law enforcement agency – resulted in significant enforcement outcomes:
✅ Conviction of a board member of a Latvian company
✅ Application of a coercive measure to the company
✅ Substantial fines imposed on both the company and the individual
✅ Confiscation of the funds that were initially frozen by the FIU
In light of the EU’s trade sanctions prohibiting the sale, supply, transfer, or export – directly or indirectly – of luxury goods (including vehicles valued over EUR 50,000) to Russia or for use in Russia, some EU companies and their representatives attempted to circumvent these restrictions. During its analysis, the FIU discovered that a Latvian company had fictitiously sold a luxury vehicle worth over EUR 100,000, misrepresenting the recipient as an individual in Central Asia while issuing documentation in Dutch. Read More