Dutch company Ellis Enterprises allegedly exported sanctioned oil products to Russia
New research suggests that Dutch company Ellis Enterprises B.V. has been illegally exporting oil products to Russia for years. The shipments, reportedly occurring thousands of times, are valued at tens of millions of euros. The exported goods, including lubricants and motor oil, are on the European sanctions list, making their sale to Russia illegal.
RTL Z’s investigation shows that the exports were identified using customs and shipping documents in the ImportGenius database, which collects trade records worldwide. These goods, crucial for machinery and vehicles, are specifically sanctioned to keep them out of Russia, especially given the war’s impact.
Ellis Enterprises serves as Valvoline’s European division, the international manufacturer of oils and lubricants, known for products like motor oil available at gas stations.
Valvoline quickly denied conducting business in Russia, claiming it neither exports to nor supplies products there. Valvoline responded to questions on sanctions compliance, stating: “We maintain strict export controls to ensure that both we and our trading partners comply with all relevant U.S. and international trade laws and sanctions.”
When presented with export documents showing Russia as the final destination, the company shifted responsibility to an intermediary, Valvoline AZ, which is a subsidiary based in Baku, Azerbaijan, which is not an EU member and does not participate in the same sanctions regime. Legal experts, however, consider this a weak defense.
The investigation suggests that Ellis Enterprises B.V., based in Dordrecht, shipped the goods to their Azerbaijani branch, which then immediately sold them to Russian distributors. Under EU law, a parent company can be held liable if it knew, or reasonably should have known, that its subsidiary was acting as a funnel into Russia.
The Dutch Ministry of Foreign Affairs said it does not comment on specific cases, but any indications of sanctions breaches are routinely investigated by regulators and, when needed, by the Public Prosecution Service. A spokesperson for the Dutch Ministry of Foreign Affairs said: “All companies in the Netherlands are required to comply with the sanctions currently in place against Russia.”
Europe introduced sanctions following Russia’s 2022 invasion of Ukraine on lubricants and motor oils that could be used in machinery, vehicles, or military applications, as they could support Russia’s economy and war efforts. Under EU and international law, exporting these products to Russia is explicitly forbidden.
While the EU has worked to limit oil exports to Russia and the facilitators of such trade, concerns remain that sanctions may be bypassed through intermediaries or rerouting via third countries.
Legal experts on sanctions warn that exporting goods under EU restrictions can carry severe penalties, such as substantial fines, potential prison terms, and the seizure of profits earned from illegal trade.
Since early 2024, the EU has mandated that exporters include a “No-Russia” clause in contracts with third-country buyers. Legal experts say that if Ellis Enterprises failed to include or enforce this clause with Valvoline AZ, it would constitute a direct breach of the 12th EU Sanctions Package.
