Two years of war in Ukraine – Finnish Customs has started more than 740 preliminary investigations relating to breaches against sanctions

Finland’s tight enforcement of sanctions has produced results in two years: 29 000 discrepancies detected in goods traffic, 2 800 targeted controls and 740 preliminary investigations started. In future, the coverage of sanctions, preventing circumvention and developing the sanctions will be even more in focus. According to Customs, corporate responsibility is essential in preventing circumvention of sanctions.

On Saturday 24 February 2024, it will be two years since the start of the war in Ukraine. The sanctions imposed against Russia by the EU due to the attack on Ukraine have been tightened along with each new sanctions package. The coverage of sanctions and uniform enforcement of sanctions in all EU countries as well as corporate responsibility are key elements in ensuring the impact of sanctions. With the latest sanctions packages, preventing sanctions circumvention has been essential.

“At first, the sanctions were effective, which we, for our part, were able to ensure through tight enforcement of the sanctions. However, sanctions should be constantly developed. From the perspective of sanctions enforcement, plugging the leaks in the range of goods better and extending the transit bans, for example, might decrease the opportunities to circumvent sanctions at the moment”, says Mr Sami Rakshit, Director of the Enforcement Department.

“At Customs we have constantly sought new enforcement measures to prevent circumvention of sanctions. In customs enforcement and in our crime prevention, we have uncovered several attempts of sanctions circumvention where, for example, forged customs documents have been used or where there have been attempts to obscure the ownership structures of businesses and the actual countries of destination for the goods transports. Diverse transport routes and modes of transport are also used when attempting to circumvent sanctions”, says Rakshit and continues:

“Constant redirecting of customs enforcement, intelligence and investigation methods is important in the prevention of sanctions circumvention. In future, one way to develop the impact of sanctions could be, for example, controls of the arrival of goods transports in certain Central Asian countries, conducted with the help of local cooperating parties.”

“In the current situation, the responsibility that businesses engaged in international trade have in the prevention of sanctions circumvention will become even more significant. If a business recognises ambiguities in its trade or logistics, it is better to give up such transactions than possibly to contribute to sanctions circumvention through one’s own actions. Knowing one’s trading partners and ensuring the final destination of the goods is of utmost importance for the EU’s common sanctions to have the appropriate effect”, says Rakshit.

Finnish Customs’ enforcement of sanctions in figures: unusual goods transports, controls and investigations

Since February 2022, Customs has done the following:

• Based on customs declarations, Customs has observed nearly 29 000 possibly unusual goods transports.
• Customs has carried out targeted controls on more than 2 800 transports.
• Customs has started preliminary investigations into more than 740 cases, nearly 100 of which are investigated as aggravated regulation offences.

Change in the number of businesses in December 2021 and in December 2023:

• December 2021: 955 Finnish businesses exporting to Russia and 480 Finnish businesses importing from Russia.
• December 2023: 98 Finnish businesses exporting to Russia and 21 Finnish businesses importing from Russia.

The closure of Finland’s eastern border has affected the transport routes of goods traffic. At the moment, only freight train traffic via the border crossing point for rail traffic at Vainikkala crosses the land border between Finland and Russia. Some of the goods traffic has transferred to another routes, via ports in Southern Finland either directly to Russia or via Estonian ports across the external border of the EU in the Baltic countries. Customs enforces sanctions and monitors potential attempts of sanctions circumvention in rail traffic and in ports in a similar way as at the border crossing points for road traffic.

Customs has estimated that before the closure of border crossing points, around 80–90 per cent of the goods traffic crossing the land border consisted of transit traffic through Finland, which has now found new routes especially through the Baltic countries.