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In Focus
Home In Focus District Court: Sanctions Circumventing Through Third Countries Led to Conviction for Aggravated Rationing Offence

Legal Updates11.09.2026

District Court: Sanctions Circumventing Through Third Countries Led to Conviction for Aggravated Rationing Offence

On 1 July 2026, the South Karelia District Court handed down a judgment in a criminal case in which the defendants were Risto Riihimäki and his company Rent ja Kalusto Oy (known as Idän Liikenteenvälitys IL Oy at the time of the offences). The case concerned the export of lorries and trailers subject to EU sanctions against Russia from Finland via third countries, effectively to Russia. The central question was whether the company’s representative had intentionally participated in exports in breach of the sanctions or whether, as he claimed in his defence, he had himself been exploited by third parties and therefore lacked the requisite criminal intent. The District Court rejected the defence and found that the evidence demonstrated that Riihimäki had been aware from the outset that the vehicles were destined for Russia. As a result, he was sentenced to three years and eight months’ imprisonment, ordered to remain in custody pending appeal, and the company was ordered to pay a corporate fine.

Background to the case and the issues at stake

The prosecutor sought convictions against Riihimäki and his company for an aggravated rationing offence on the grounds that the company had exported a total of 164 lorries and trailers from Finland to Russia in breach of Article 3 k of Council Regulation (EU) No 833/2014, even though the export of such vehicles to Russia had been completely prohibited since July 2022.
According to the prosecutor, the vehicles had formally been sold to the Kazakh companies Servitut LLP and Sandyk Cargo LLP, as well as to the Turkish company Byzantium Transport. In reality, however, the vehicles never reached, nor were they intended to reach, the declared countries of destination but instead remained in Russia. The prosecutor argued that the arrangement was artificial and had been designed to conceal the actual purchaser and recipient of the vehicles, the Russian company OOO Liverpool (EuroTruck Perm). According to the prosecution, the use of Russian-controlled entities in Kazakhstan and Turkey, together with Idän Liikenteenvälitys as an intermediary, served to disguise the true destination of the vehicles and thereby circumvent the sanctions regime.
Riihimäki denied the charges and claimed that he had been the victim of exploitation. According to his account, he believed that the vehicles were genuinely being sold to Kazakh companies and did not consider it likely that they would ultimately end up in Russia. The defence argued that he had acted under a mistake as to the constituent elements of the offence, thereby excluding intent. The defence further pointed out that the applicable criminal provision derived its substantive content from EU sanctions legislation, which could be difficult for an ordinary individual to interpret. Riihimäki also disputed the allegation that the operation had been particularly systematic, arguing that his role had merely consisted of purchasing vehicles in Europe and selling them to customers in Kazakhstan, while any broader scheme had been organized by others.

The District Court’s ruling

The principal issues before the District Court were whether Riihimäki had acted intentionally, whether he had been operating under a mistake of fact or a mistake of law that would exclude criminal liability, and, if not, whether the conditions for an aggravated form of the offence were met. The District Court’s key conclusion was that Riihimäki’s claim that he had been unaware of the vehicles’ actual destination was not credible and that the evidence demonstrated intentional conduct throughout the operation.
The District Court emphasized that intent could not be assessed directly on the basis of the defendant’s own account but had to be inferred from the totality of the circumstantial evidence, considering his previous experience of similar trade in Russia. Decisive weight was attached to the fact that Riihimäki had provided false information to a long-standing Finnish business partner regarding the intended use and destination of the vehicles already during the initial negotiations. There would have been no reason for such misrepresentations had the exports genuinely been lawful. A particularly compelling piece of evidence was an email sent in February 2023, the attachment to which explicitly listed the vehicles as being for sale to Russia. The District Court held that, at the latest upon receiving that email, Riihimäki must have been aware of the vehicles’ actual destination.
The District Court further held that the explanations Riihimäki had provided to business partners and financial institutions that questioned the transactions did not support his claim of ignorance. On the contrary, the Court noted that those explanations contained inaccurate and false information and therefore indicated awareness of the true nature of the arrangement. The Court also attached significance to evidence showing extensive communication with representatives of the Russian company OOO Liverpool and to the use of email addresses linked to the Russian domain “eurotruck-perm.ru”. On these grounds, the District Court found that Riihimäki had not acted under a mistake as to the constituent elements of the offence. The defence’s reliance on a mistake of law was also rejected, as the relevant export prohibition had been introduced through a duly published amendment to Regulation 833/2014 and that Riihimäki himself had acknowledged having actively followed sanctions-related announcements.
In addition to intent, the District Court found that the offence was aggravated since the scheme was based on an artificial arrangement intended to conceal the true purchaser, the activity was extensive both in duration and monetary value, it was carried out with the aim of obtaining substantial financial gain, and false registration certificates had been used in an attempt to conceal the vehicles’ destination. Regarding the company, the District Court held that the offence had been committed in the course of the company’s business. The vehicles had been acquired, sold and exported in the company’s name, and Riihimäki, as the sole shareholder and the person exercising de facto decision-making authority within the company, had acted on its behalf and for its benefit. Accordingly, the District Court found both Riihimäki and the company guilty as charged. In addition to imposing criminal penalties, the District Court ordered the defendants jointly to forfeit approximately EUR 608,000 in criminal proceeds and EUR 6 million representing the value of the exported vehicles.

Assessment of the ruling and its practical implications

It is noteworthy that the District Court’s judgment structures the assessment of intent into a clear and traceable timeline. The District Court identified a specific piece of evidence – an email sent in February 2023 – from which point onwards Riihimäki’s awareness was considered unequivocally established. However, the Court did not limit its analysis to that single item of evidence. It separately examined the preceding period and concluded, on the basis of several mutually supporting factors, such as false information provided to business partners and unusual indifference towards the background of trading partners, that Riihimäki had in fact been aware of the vehicles’ destination from the outset.
From a compliance perspective, the ruling is particularly relevant for companies operating in the export, transport and logistics sectors that conduct business with high-risk jurisdictions or their neighbouring countries that may serve as transit routes for goods ultimately destined for sanctioned countries. The ruling reinforces the principle that economic operators must actively investigate the background of a trading partner and assess circumstances that point to a risk of sanctions circumvention. A deliberate failure to inquire further, or reliance on explanations that are manifestly questionable, may not be sufficient to avoid criminal liability.
Both defendants have lodged notices of dissatisfaction with the District Court’s judgment. Attention therefore turns to the Court of Appeal, which is expected to reassess at least the following questions:

• Where should the line be drawn between ordinary commercial risk-taking and conduct that demonstrates sufficient awareness of sanctions circumvention to establish criminal intent?
• How much weight can be attached to a single item of documentary evidence, such as the ‘Sell to Russia’ email, when determining a defendant’s state of mind?
• How should courts assess the proportionality of a forfeiture order where the value of the assets subject to forfeiture is many times greater than the financial benefit obtained from the offence?

It remains to be seen whether the Court of Appeal will endorse the District Court’s rejection of the defendant’s arguments concerning mistake of fact and mistake of law, as well as its assessment of the proportionality of the forfeiture order. The outcome is likely to have significant implications for the level of due diligence expected from companies engaged in exports and international trade when managing sanctions compliance risks.

For more information

Olli Kiuru

Partner

Sami Hartikainen

Counsel

Linda Nyman

Counsel

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