European Sanctions Enforcement

July 20, 2026July 20, 2026 by Mark Handley

United Kingdom – sanctions enforcement statistics for HMRC in 2025/26

The UK’s HMRC has released enforcement statistics for 2025 and the first part of 2026 in a “Technical Note”:

22 criminal investigations with three charges and two (at the time of the release of the Note) pending trial;
58 seizures of sanctioned goods
1 compound penalty of £1,160,725.67 (see our previous post);
29 self-disclosures, with these being resolved as follows:
- 18 warning letters;
- 7 no further action letters;
- 1 compound penalty;
- 3 cases remain unresolved.

By way of cooperation with the Office of Trade Sanctions Implementation, there were 44 referrals to HMRC in 2025/2026, with 10 resulting in no further action, 13 relating to already-ongoing investigations; and 21 still under review.

July 20, 2026July 20, 2026 by Mark Handley

United Kingdom – charges dismissed against art gallery and transporter

Further to our earlier post, on 9 July, the charges against the art gallery Hauser & Wirth, and art logistics company Artay Rauchweger were dismissed on the basis of a pre-trial application. The dismissal was first reported by GIR behind a paywall.

The charges related to an allegation that the gallery sold a painting to a “person connected with Russia”. The relevant statutory definition (in regulation 19A(2)(a) of the UK’s Russian sanctions regulations), is that the person must be either “ordinarily resident in Russia” or “located in Russia”. The focus for the court was the first test.

The judge held that a properly directed jury would be unable to find that there was sufficient evidence that the buyer of the artwork was “ordinarily resident” in Russia at the time of the sale in July and August 2022.

The prosecution produced evidence of a continuing connection to Russia, but the judge is reported to have held that “the statutory test is not one of continuing connection, nationality or association, but ordinary residence”.

July 20, 2026July 20, 2026 by Mark Handley

Poland – investigation into timber imports instigated by the EPPO

The European Public Prosecutor’s Office (EPPO) has issued a press release relating to an investigation in Poland into suspected Russian sanctions breaches.

The Municipal Police Headquarters in Katowice and the Silesian Customs and Tax Office – Częstochowa Branch, have responded to a request for assistance from the European Public Prosecutor’s Office (EPPO) in conducting an investigation related to customs and VAT fraud, as well as sanctions breaches, arising from the importation of birch wood into Poland between October 2023 and April 2025.

The company being investigated is alleged to have falsely declared the origin of the timber as Kazakhstan, when it is alleged to have actually originated from Russia.

July 20, 2026July 20, 2026 by Mark Handley

United Kingdom – bail denied and trial date set for prosecution of captain of the tanker Smyrtos

Further to our earlier post, it is being reported that a hearing took place in London on Thursday of last week relating to the prosecution of Ajay Pant, the Indian national who was captain of the oil tanker the MV Smyrtos.

As part of the hearing Pant’s application to be released on bail was refused and a four week trial was listed to start on 15 December.

In addition, the court has scheduled a hearing on 12 November to hear an application by the defendant to have the charges dismissed. The reporting does not mention the basis for that application.

July 20, 2026July 20, 2026 by Mark Handley

Netherlands – investment bank fined €8.5m for compliance failures, including sanctions

The Dutch DNB has issued an administrative fine to ABN Amro relating to compliance failings.

The fine was reduced from €10m to €8.5m as part of a settlement with the bank.

The sanctions element relates to a number of the customers included within the DNB’s investigated sample. As part of the assessment of these client files it was determined that there was an unaddressed risk that some of the clients were involved with dual-use goods with some indicators that the bank’s customers were using intermediaries in high-risk jurisdictions to evade or circumvent the EU’s Russian sanctions. The bank was also criticised for undue reliance on uncorroborated client declarations.

July 6, 2026July 6, 2026 by Mark Handley

Estonia – details of 5 criminal convictions for sanctions breaches

The Estonian case law website has made available a number of further judgments relating to convictions for sanctions offences:

Case 1. Judgment dated October 6, 2025

This case was the prosecution of Mati-Dmitri Terestal (see our earlier post). It was alleged that he, and another, had made economic resources and find available to a designated person who was the head of Yle1 (a Russian state-owned media outlet). It was alleged that Terestal continued to operate the media outlet after it had been closed, through a front entity and had continued to provide economic resources in the form of technical equipment, and other assets.

It was also alleged that by hiring staff for the company this was making economic resources available to Yle1, as was the creation of web domains.

The County Court had convicted Terestal in January 2025, and sentenced him to 2 years and 4 months, this was suspended for three and a half years. He was also fined €7882.92.

The District Court disagreed with the County Court on a number of issues (including whether hiring staff without more amounted to the making available of an economic resource, but upheld the conviction. The sentence was unchanged.

The decision includes a discussion of the characteristics of control for asset freeze purposes.

Case 2. Judgment dated January 21, 2026

The prosecution entered into an agreement with the defendants that was upheld by the court following guilty pleas by the defendants.

The defendants (a company and a director that company) had set out to create a fake network of transactions and sales in order to import bitumen from Russia in breach of the EU’s sanctions. The fake transactions involved front companies in a range of jurisdictions including Kazakhstan and Hong Kong. One member of staff (who was either not prosecuted or separately prosecuted) had the role of maintaining a watching brief on changes to the EU’s sanctions in order to develop changes to the methodology for masking the Russian imports.

The company, Keystone Shipping OÜ, was fined €250,000, ordered to pay costs of €61,928.18 and had bitumen valued at €179,200 confiscated.

Andrey Kolesnikov, the sole director of the company, was fined €32,110 and costs of €1,329.

Case 3. Judgment dated March 6, 2026

The case was an appeal to the District Court from a judgment of the County Court which had found two men guilty of attempting to export a BMW car to Russia in breach of the EU’s sanctions against the export of luxury goods. Vladimir Palamarchuk was fined €3000 and Igor Palamarchuk was fined €2000. In addition the car, valued at over €50,000, was confiscated as the proceeds of crime.

The appeal, which was largely based on whether the car exceeded the 50,000 threshold, was denied and the fines and confiscation upheld.

The judgment relied on the EU’s FAQs in relation to the process for determining the price of an exported good.

July 6, 2026July 6, 2026 by Mark Handley

France – guilty plea for Tagor tanker owner leads to €1m fine and release

Further to our earlier post regarding the detention by the French authorities of the oil sanctioned shadow fleet tanker, the Tagor, on 2 July, the company owning the vessel pleaded guilty in a Brest court to failing to be flagged and a refusal to comply with an order.

The company was fined, and paid, a fine of €1m. Upon payment the vessel was released and the is now sailing for Istanbul.

Our European Vessel Seizure Tracker has been updated.

July 2, 2026July 2, 2026 by Mark Handley

Germany – mid trial guilty pleas for two charged with 65 equipment shipments to Russia

Further to our earlier post, mid trial two brothers have pleaded guilty to breaching the EU Russian sanctions as part of an agreement with the prosecution.

They were accused of shipping 65 consignments of engineering and industrial equipment to Russia valued at €830,000 between 2023 and 2024.

As part of the agreement both men have accepted that they face 4 year custodial sentences. The verdict of the court is awaited.

The father of the two men is being separately prosecuted.

July 2, 2026July 6, 2026 by Mark Handley

Finland – conviction for Russian truck exports with 3 years and 8 months jail and €6.6 million confiscated

Further to our earlier posts (here, and here, and here), Risto Riihimäki has been convicted of aggravated sanctions breaches for his role in the export of 135 trucks to Russian in breach of the EU’s sanctions.

The trucks were declared to be transiting through Russia, but that was actually their final destination.

Mr Riihimäki was the CEO of the company Idän liikennevälitys IL Oy, and he has been sentenced to jail for three years and eight months, just below the 4 year maximum sentence for the offence under Finnish law.

In addition, the court has imposed confiscation order for €608,275 against Mr Riihimäki as the proceeds of crime, and a confiscation order against the company for profits it obtained from the exports in the sum of €6m. The company was also fined €10,000.

Although two other employees had originally been the subject of the investigation, ultimately they were not charged.

The conviction and sentence remain subject to appeal.

June 29, 2026June 29, 2026 by Mark Handley

UK – compound penalty of £569,157 imposed on named energy company

The UK’s HM Revenue and Customs has announced the imposition of a compound penalty of £569,157 on Petrofac Facilities Management Limited.

This is the first time, in a long time, that HMRC has named the recipient of a compound penalty.

The breaches took place in 2022 and 2023 with the company supplying prohibited goods to individuals connected with Russia and also providing technical assistance in relation to those goods.

The company subsequently self-reported and cooperated with the investigation.

The change in naming policy is addressed:

“Naming those involved brings us into line with other enforcement partners whilst sending a clear message on the consequences of breaching sanctions rules.”

The Notice further states that “Where appropriate, HMRC will now include naming as a condition when offering a compound settlement for strategic export and sanctions offences“. It appears that naming will now become more common if not done universally.

The Notice also gives helpful guidance on when HMRC will consider a compound penalty rather than prosecution, noting that a penalty will only be pursued where HMRC considers it has enough evidence to prosecute, and other considerations, including:

the seriousness of the alleged offence;
whether fraudulent intent can be proven;
the extent of the efforts to perpetrate the alleged offence;
the type and value of any goods involved;
the offender’s previous history;
the extent to which the offender has co-operated with any investigation; and
the level of financial penalties known to have been imposed by courts for similar offences.