European Sanctions Enforcement

September 9, 2026September 9, 2026 by Mark Handley

The blog’s 800th post – fines and jail terms

It was only in March that the blog passed the milestone of 700 posts, and now it is at 800. To mark the occasion we are publishing some graphs on the current state of enforcement across Europe.

Fines

The first graph shows (in blue columns) the annual values (in euros) of fines/confiscations/penalties/forfeitures for sanctions breaches across Europe from 2017 to 2026.

The green line is the number of fines in any given year valued at €1 million or more.

With nearly four months to go 2026 is at €115.3m and is on track to surpass both 2024 and 2019 in terms of total value (and 2019 had a single fine of £102m from the UK’s FCA).

What the graph also illustrates is that while 2018-2020 had a small number of very large fines, countries across Europe are now imposing a much higher number of significant fines than before.

Jail terms

The next graph is another way of showing the sea change in enforcement outcomes since 2022.

In the last three years over 175 years of jail time (not including suspended sentences) have been handed down. The adoption and implementation of the EU’s harmonization directive, is only going to reinforce and further drive this trend as more member states take on the power to impose a custodial sentence.

September 9, 2026September 9, 2026 by Mark Handley

UK – HMRC issues £7.4m penalty for supply of goods to Russia

The UK’s HM Revenue and Customs has issued its largest sanctions-related Compound Penalty to date.

The company, Illumina Cambridge Limited, was fined £7,438,840.13 for breaches of the UK’s Russian sanctions.

The published Notice gives limited information on the breaches:

“Between July 2022 and January 2023 Illumina breached regulation 25(1) through their involvement in the supply of sanctioned goods from one overseas company within their corporate group to another overseas company within their corporate group for export to Russia and other destinations“.

Regulation 25(1) prohibits the direct or indirect making available of “restricted goods” or “restricted technology” either for use in Russia, or to a person connected with Russia.

Illumina Cambridge Limited voluntarily disclosed the conduct to HNRC and cooperated with the investigation.

As noted by HMRC “sanctions breaches can occur when UK businesses are involved in supply chains that result in sanctioned goods being supplied indirectly to Russia (or other countries subject to trade sanctions), even when no goods have been exported from the UK“.

This is the third large fine/forfeiture handed out by UK authorities in the last few weeks following the £4.7m fine from OFSI (2 September) and the $5.2m forfeiture from the National Crime Agency (27 August).

September 4, 2026September 4, 2026 by Mark Handley

Luxembourg – CSSF imposes fine for AML and sanctions compliance violations

In an Administrative Sanction published by Luxembourg’s CSSF, a fine of €56,000 was imposed on Stonehage Fleming Luxembourg S.A.

Most of the notice relates to AML compliance failings, but included was a complaint as regards to the resolution of sanctions screening hits and a delay in implementing changes to lists for screening purposes:

“At the time of the on-site inspection, hundreds of name screening alerts had been treated with significant delays and 42 alerts remained unnoticed by the PFS. These delays constitute a breach of the obligations foreseen in Article 3(2) point (d) of the AML/CFT Law and in Article 33(1) of CSSF Regulation No 12-02, as the PFS was unable to identify “without delay” persons subject to restrictive measures in financial matters and therefore apply “without delay” potential restrictive measures in financial matters as the case may be“.

September 4, 2026 by Mark Handley

Sweden – extradition of Russian national to the US approved to face sanctions charges

It is being reported (here, behind a paywall), the Sweden’s Supreme Court has approved an request for a Russian national to be extradited to the United States to face charges arising from the alleged export of military components to Russia via Hong Kong.

September 4, 2026September 4, 2026 by Mark Handley

Luxembourg – investigation into alleged Russian sanctions breaches discontinued

Further to our earlier post regarding a Luxembourg investigation into possible EU sanctions breaches by the company Spacety Luxembourg SA, it is now being reported that the Luxembourg authorities have discontinued the investigation.

A government spokesperson is reported to have stated that the investigation was discontinued after several mutual legal assistance requests had been made, but it is unclear whether these requests were refused, and to which countries the requests were sent.

The company was placed into liquidation in October 2025.

September 3, 2026September 3, 2026 by Mark Handley

Czechia – police refer sanctions evasion case to prosecutors

Further to an earlier post, it is being reported that police investigators from Czechia’s National Centre for Combating Organized Crime, who have been investigating alleged breaches of the asset freeze imposed on a designated person under the EU’s Russian sanctions, have now handed the case file to prosecutors for a final charging decision.

It is alleged that Dmytro Kalantyrskyi conducted multiple transactions in 2015 relating to frozen funds in the value of CZK 96 million (nearly €4m).

September 3, 2026September 3, 2026 by Mark Handley

Latvia – Customs confiscates €15m in sanctioned goods

A broadcast news story has provided data on the enforcement activity of Latvia’s Customs.

The story reports that:

roughly twice a week a shipment of sanctioned goods to Russia is stopped;
30 cargoes of military goods have been stopped; and
Customs have confiscated €15m in sanctioned goods through its work at inspections at checkpoints, of which roughly €3m has so far been sold.

The new story does not state over what period the confiscations took place.

September 2, 2026September 2, 2026 by Mark Handley

UK – OFSI imposes fine of £4.73m on investment bank

The UK’s Office of Financial Sanctions Implementation has issued a Penalty Notice against Citibank NA in the amount of £4,732,830.58.

This is OFSI’s second largest fine since it was launched.

The fine relates to 970 payments in breach of the UK’s Russian sanctions with a total value of £19,720,127.32 with most of the payments taking place in the months after February 2022.

OFSI have Citibank a 20% voluntary self-disclosure and cooperation credit (and not the permissible 30%). The bank had voluntarily self-reported many of the breaches and payments, but was unaware of £6.9m of the payments being breaches until OFSI started to raise questions.

OFSI also provided Citibank with a 20% discount based on agreeing a settlement, under OFSI’s fairly new settlement methodology.

These discounts, against a starting point where the maximum fine is 50% of the value of the breaches, resulted in the penalty amount. It is worth noting that the new Chancellor has announced plans to increase the maximum fine to 100% of the value of the transfer.

The breaches all related to failings and delay in screening customers, recipients and correspondent banks. While OFSI’s Notice expresses sympathy with the high volume of designations that took place in 2022, it was critical of Citibank’s level of preparedness in the run up to February 2022 and of the high volume of errors including changes in policy that made the prevention of payments more difficult. OFSI also was critical of the time taken for the bank to report that it was holding frozen assets.

September 1, 2026September 1, 2026 by Mark Handley

EU – further sanctioned oil tanker, the MV Sun, boarded in Mediterranean

Further to our earlier posts (here and here) regarding the tanker boardings by the EU’s operation EUNAVFOR MED Irini, it is being reported that yesterday the same EU operation has boarded the sanctioned tanker MV Sun south of Sicily.

The boarding was conducted by an Italian naval vessel on behalf of the EU operation.

The inspection was to verify and determine the flag status of the vessel, and the vessel does not appear to have been detained.

September 1, 2026September 1, 2026 by Mark Handley

Georgia – investigation into suspected sanctioned exports to Russia

The Georgian authorities have announced an investigation arising from a Azerbaijani-registered lorry attempting to cross from Turkey into Georgia in July.

The investigation arose from checks carried out at the Sarpi checkpoint. During an inspection of a lorry, the driver declared that the goods were of EU origin and were destined for Russia. The lorry was turned back.

Later the same day the lorry returned to the same checkpoint and this time the goods were accompanied by documents asserting a Turkish origin. Inspection revealed the goods to have had German and Croatian origin.

The case has been referred to the Investigation Service of Georgia’s Ministry of Finance for further action with offences of breaching sanctions and forgery the subject matter of the investigation.