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UAB Clean and Solve — €534k frozen, no indictment in 18 months

On 27 May 2025 the Vilnius Regional Prosecutor froze €534,351.88 of UAB Clean and Solve, a Vilnius-registered chemicals trader owned by two Dutch citizens. The substance — gamma-butyrolactone (GBL), an EU REACH-registered chemical with thousands of legitimate industrial uses — moved from a German producer to a Czech warehouse to a Dutch buyer. The goods never entered Lithuanian territory. Eighteen months later, the freeze has been extended to November 2026 and no formal indictment has been filed.

Company
UAB Clean and Solve
Jurisdiction
Vilnius, Lithuania
Assets frozen
€534,351.88
Months under freeze
18+

The narrative

In 2016, Onne Frederikus Gerardus Lelie obtained Lithuanian citizenship in addition to his Dutch passport. Together with his business partner Job Van Den Berg, he founded UAB „Clean and Solve“ (code 304231452), a Vilnius-based chemicals trader registered under the EU REACH regulation with the European Chemicals Agency.

The company’s core business was the cross-border trade of gamma-butyrolactone (GBL, EC 202-509-5, CAS 96-48-0) — a substance with thousands of legitimate industrial applications, from resin and polymer manufacturing to electronic-component cleaning, paint stripping and metal degreasing. Across five years, the trade route was consistent: VladaChem (Germany) → Transforwarding/Quick Delta warehouse (Czech Republic) → Trade Chemicals Europe BV (Netherlands). The cargo never physically entered Lithuanian territory.

In November 2018, Lithuania amended its national Schedule IV to add GBL to its list of regulated substances. The amendment was a unilateral national measure: it diverged from the EU’s REACH framework and was not reflected in the regulation of any neighbouring EU member state. CLSO, like other traders, continued to operate under EU rules.

On 27 May 2025, the Vilnius Regional Prosecutor’s office, under investigation No. 01-1-44850-24 led by prosecutor Edmundas Bagdonas, ordered a temporary freeze of €534,351.88 across CLSO’s bank accounts and assets. The freeze was framed under article 202(1) of the Lithuanian Criminal Code (unlawful business activity). At that moment, no formal indictment had been issued.

Each judicial review upheld the freeze. Judge Mikužytė (July 2025), Judge Telksnienė (August 2025 appeal), Judge Bakanauskaitė (November 2025) and Judge Balkaitienė (May 2026) successively confirmed the prosecutor’s measure. None engaged in substance with the EU-law arguments raised by the defence: the free movement of goods under TFEU articles 34–36, the supremacy of REACH in chemical regulation across the single market, or the controlling precedent of the EFTA Court in case E-9/16 (Norway v ESA, PFOA).

When defence counsel began to win interlocutory arguments, the prosecutor’s office added new theories of liability. November 2025 saw the addition of article 216(1), money laundering. May 2026 saw the addition of article 260(3), handling of narcotic precursors. With every escalation, the freeze was extended — most recently to November 2026, taking the total period of asset incapacitation to eighteen months and counting.

As of May 2026, no charge has been confirmed by any trial court. No EU-law issue has been referred to the Court of Justice of the European Union, despite the defence’s repeated requests under Article 267 TFEU. The owners continue to seek redress through every available channel — national, European and international — and have agreed to publish the primary documents so the public can verify the record for itself.

Timeline

  1. 1 Jan 2016
    Citizenship granted
    Onne Lelie obtains Lithuanian citizenship.
  2. 1 Nov 2018
    Lithuania adds GBL to Schedule IV
    National measure diverges from the EU REACH regime; not reflected in any neighbouring member state.
  3. 1 Mar 2019
    CLSO begins cross-border GBL trade
    Germany → Czech Republic → Netherlands. Goods never enter Lithuania.
  4. 27 May 2025
    Vilnius prosecutor freezes €534,351.88
    Investigation No. 01-1-44850-24, Edmundas Bagdonas. No formal charge.
  5. 15 Jul 2025
    First judicial review upholds freeze
    Judge Mikužytė. EU-law arguments not engaged.
  6. 20 Aug 2025
    Appeal rejected
    Judge Telksnienė. No referral to CJEU.
  7. 10 Nov 2025
    Money-laundering charge added
    Article 216(1) added. Freeze upheld by Judge Bakanauskaitė.
  8. 15 May 2026
    Narcotic-precursor charge + freeze extended
    Article 260(3) added. Judge Balkaitienė extends freeze to November 2026.

Documented violations

TFEU Art. 34–36

Free movement of goods

Lithuania’s national Schedule IV creates a measure of equivalent effect by restricting cross-border GBL trade among EU member states even when the goods do not enter Lithuanian territory.

REACH Reg. (EC) 1907/2006 Art. 128

Free movement under REACH

GBL is registered under REACH and lawfully placed on the EU market. The Lithuanian freeze treats trade in this substance as criminal conduct in breach of REACH Article 128.

EU Charter Art. 17

Right to property

An 18-month asset freeze without formal indictment is a disproportionate interference with property in the meaning of Article 17.

EU Charter Art. 47

Right to an effective remedy

Judicial reviews that fail to engage with substantive EU-law arguments amount to a denial of effective remedy.

ECHR Art. 6

Right to a fair trial

Eighteen months without indictment, with escalating charges and repeated extensions, undermines the reasonableness and fairness required by Article 6.

ECHR Art. 7

No punishment without law

Treating EU-lawful trade as criminal under national lists — retroactively or against a backdrop of EU supremacy — violates the foreseeability requirement of Article 7.

ECHR Art. 1, Protocol 1

Protection of property

A protracted asset freeze without indictment is an interference disproportionate to any legitimate aim.

ECHR Art. 13

Right to an effective remedy

Repeated judicial reviews that decline to engage with the EU-law arguments do not constitute an effective domestic remedy.

Lithuanian Constitution Art. 23

Right to property

A freeze of working capital without timely indictment is incompatible with Article 23.

Lithuanian BPK Art. 151

Temporary restraint of property rights

Eighteen months without indictment, with serial extensions, exceeds the conditions envisaged by Art. 151.

ICCPR Art. 14

Equality before the courts

Differential treatment that disadvantages foreign-owned business undermines Article 14.

EFTA Court E-9/16 (Norway v ESA)

Proportionality in chemical restrictions

Lithuanian Schedule IV restrictions on a REACH-registered substance are not proportionate within the meaning of E-9/16.

Filed documents

press28/05/2026
Lithuania Legal Watch Press Release — 18-Month Anniversary
Editorial press release marking 18 months of asset freeze without indictment.
Awaiting clearance
court_rulings15/05/2026
Judge Balkaitienė — Extension to Nov 2026 + 260(3)
Freeze extended to November 2026; narcotic precursor charge under BK 260(3) added.
Awaiting clearance
legal_analysis20/02/2026
Proportionality Analysis under EFTA E-9/16
Application of the EFTA Court’s proportionality test to Lithuania’s Schedule IV measures.
Awaiting clearance
legal_analysis15/01/2026
Editorial Legal Memorandum — EU-law Violations
Detailed analysis mapping the facts of the case to specific articles of EU law, the ECHR and the Lithuanian Constitution.
Awaiting clearance
court_rulings10/11/2025
Judge Bakanauskaitė — Extension + AML Charge
Freeze extended; money laundering charge under BK 216(1) added.
Awaiting clearance
correspondence01/09/2025
Request for CJEU Article 267 Referral
Defence motion requesting national court to refer EU-law questions to the Court of Justice. Refused.
Awaiting clearance
court_rulings20/08/2025
Judge Telksnienė — Appeal Decision
Appeal rejected. No referral to CJEU.
Awaiting clearance
court_rulings15/07/2025
Judge Mikužytė — First Review Decision
Court decision upholding asset freeze. EU-law arguments raised in defence not addressed in reasoning.
Awaiting clearance
correspondence10/06/2025
Defence Letter to Prosecutor on REACH supremacy
Formal letter setting out REACH Art. 128 and TFEU Art. 34–36 arguments. No substantive response received.
Awaiting clearance
court_rulings27/05/2025
Vilnius Prosecutor Order — Asset Freeze (27 May 2025)
Initial order freezing €534,351.88 across all CLSO bank accounts under article 202(1) BK. Investigation No. 01-1-44850-24.
Awaiting clearance
evidence10/03/2024
Logistics Documentation — Germany → Czech → NL Route
CMR notes and customs filings demonstrating that goods never entered Lithuanian territory.
Awaiting clearance
evidence01/06/2019
REACH Registration — GBL
European Chemicals Agency registration dossier for GBL.
Awaiting clearance