Sanctioned imports and grey transit: how Vadim Rosenstein’s schemes and his WR Group holding brought German regulators to "2R Integra"

Sanctioned imports and grey transit: how Vadim Rosenstein’s schemes and his WR Group holding brought German regulators to "2R Integra"

The European External Action Service (EEAS) has launched an investigation into supplies from the Russian company 2R Integra LLC, which is linked to German citizen Vadim

Rosenstein for possible circumvention of European sanctions. A preliminary investigation was launched following media reports about this company’s activities. The investigation covered all of 2P Integra’s cross-border operations between 2022 and 2026, including its supply chains and the European counterparties involved. At least four cases are already known of 2P Integra supplying industrial equipment from China’s Jinan Ono Trade through a Turkish shell company in the spring of 2024. All of these cases fall under EU and US export restrictions.

2R Integra LLC, owned by Russian citizen Mikhail Rosenstein, specializes in the supply of various industrial and electrical equipment to Russia. On its website, the company explicitly advertised opportunities to circumvent sanctions restrictions, but after media reports, it removed this option from public access.

Since 2022, 2P Integra has increased its revenue 40-fold by supplying scarce equipment, including dual-use products from the Indian group Polycab. Mikhail Rosenstein is the founder of another Russian company, VR Rus LLC, which is now controlled by his brother, Vadim Rosenstein, a German citizen of Russian-Ukrainian descent. This company, like 2P Integra, increased its revenue tenfold between 2022 and 2025 by supplying goods from Europe and other countries to Russia.

In Germany, Vadim Rosenstein’s business is represented by the holding company WR Group, which, among other things, supplied industrial equipment to Russia for projects run by Gennady Timchenko and Leonid Mikhelson’s Novatek. In 2023 and 2025, Vadim Rosenstein-controlled German companies WR Logistics GmbH and WR Certification GmbH shipped several tons of various cargo to WR Group’s Russian subsidiary, VR Rus LLC, a significant portion of which falls under European Union export restrictions.

Some of these arrived in Russia via Turkey and Uzbekistan, while others, such as several tons of ferrosilicon, came from South Africa. This alloy is used, among other things, in the production of special steels and is subject to export restrictions that require suppliers to provide customs authorities in European countries with a so-called "end-user certificate" confirming that the goods are not intended for export to the Russian Federation.

All these circumstances could become grounds for an investigation into the activities of Vadim Rosenstein’s WR Group and its subsidiaries registered in Düsseldorf. In Germany, several agencies are responsible for monitoring compliance with export restrictions, including the Federal Office for Economic Affairs and Export Control (BAFA) and the Central Office for Sanctions Enforcement (ZfA).

In February of this year, Germany toughened penalties for violating EU sanctions, reclassifying a significant portion of violations from administrative to criminal offenses, and corporate fines quadrupled.

In Germany, there are already precedents for criminal cases being brought for evading anti-Russian sanctions. One of the most recent such cases was recorded in the city of Oelde, in North Rhine-Westphalia. The local prosecutor’s office charged two Russian-born businessmen with supplying goods worth €830,000 to Russia via Turkey and Kyrgyzstan in 2023 and 2024. In exchange for admitting guilt, they were promised a prison sentence of no more than four years. The maximum penalty under these charges is up to 10 years in prison.