European Sanctions Enforcement

January 22, 2026January 22, 2026 by Mark Handley

Cyprus – Securities and Exchange Commission refers sanctions cases to police and Attorney General

As part of a press conference setting out the various strands of work conducted by the Cyprus Securities and Exchange Commission, information has been provided on sanctions enforcement:

“What is more, enhanced monitoring was conducted on entities with current or past exposure to persons subject to EU restrictive measures against Russia.

Cases involving potential breaches of sanctions were forwarded to the police and the attorney general for further investigation, with relevant information also shared with the National Sanctions Implementation Unit established under the new sanctions framework that entered into force in July 2025“.

It was also stated that CySEC had imposed total fines and penalties of €2.3m during 2025 but no information is given to indicate that any of this sum related to sanctions fines. The CySEC website itself does not include the details of any fines in 2025.

January 22, 2026January 22, 2026 by Mark Handley

Germany – two arrested for providing funds and economic resources to Donetsk and Luhansk People’s Republics

Germany’s Federal Public Prosecutor has issued a press release relating to the arrest of two individuals for supplying funds and economic resources to the sanctioned Ukrainian separatist groups the Donetsk and Luhansk People’s Republics.

It is alleged the two individuals, Suren A. (Russian) and Falko H. (German) transferred €14,000 to these groups and also organised the transport of supplies, drones and medical products to them.

The press release mentioned raids of May 2025 in Berlin and Brandenburg, including of a third suspect.

January 19, 2026January 19, 2026 by Mark Handley

Germany – maritime authorities turn away shadow fleet vessel

Last week the German authorities ordered the vessel Tavian not to enter German territorial waters after inspection of the ship’s papers resulted in a finding that the vessel was sailing under a false flag and with a fake IMO number, and a suspicion that the tanker was being used to ship Russian oil.

The vessel complied with the order and turned around before returning to the North Sea and turning off its transponder.

Other reports include a comment from the Bundespolizei that they could not comment on an “ongoing operational procedure”.

January 19, 2026January 19, 2026 by Mark Handley

Portugal – prosecution brought against football club for receiving payment from sanctioned Russian club

It is being reported (and here behind a paywall) that Portuguese football club Casa Pia, and the clb’s executive manager, are being prosecuted by Portugal’s Public Prosecutor’s Office for an alleged breach of the EU’s sanctions.

The allegation is that the club received €1.5 million from the Russian football club FC Akhmat in payment for a player transfer.

FC Akhmat is said to be owned by Ramzan Kadyrov, who is a designated person under the EU’s sanctions.

Reports also state that the indictment includes accusations of forgery and money laundering as part of deceiving the club’s bank as to the origin of the funds.

January 19, 2026January 19, 2026 by Mark Handley

Italy – investigation and vessel seizure for alleged cargo of Russian metal

Italy’s Guardia di Finanza and Customs Agency have seized a vessel in the port of Brindisi as part of an investigation into the alleged import of 33,000 tons of ferrous metal in breach of the EU’s Russian sanctions.

Through vessel tracking, including the time and location of the vessel turning off its transponder, the Italian authorities allege that the vessel was loaded at the port of Novorossiysk.

Other reporting has named the vessel as Tuvalu flagged Hizir Reis.

January 15, 2026January 15, 2026 by Mark Handley

Estonia – Tax and Customs Board sanctions enforcement statistics

As of 14 October 2025, the Tax and Customs Board of Estonia has started to publish weekly summaries of its activity, including the enforcement of sanctions at the various customs points with Russia.

Based on these weekly summaries the identification of a sanctions breach by customs officials results in one of four outcomes: 1) the import/export is prevented without further actins being taken; 2) an investigation is commenced; 3) a criminal proceeding for a misdemeanour offence is started; or 4) an on-the-spot fine is issued.

Based on the weekly reports since mid October, the following enforcement actions in categories 1-3 can be identified:

3 investigations started;
10 criminal prosecutions for misdemeanour offences started;
14 on-the-spot fines, imposed, with values of €120, €304, €600, €1600, €1600, €800, €80, €240, €800, €600, €800, €400, €800 and €2000 (total of €10,744).

The offending is dominated by the small-scale carriage of luxury goods and euro notes.

The weekly summaries that include sanctions enforcement can be found here:

In addition, back on 18 August 2025, the Tax and and Customs Board published a half-yearly sanctions enforcement update – not previously reflected here.

This identified the following enforcement statistics:

585,000 identified border crossings
4,300 sanctions violations detected (said to be down 1,000 from the previous year)
on-the-spot fines of c. €93,000 imposed
413 misdemeanour proceedings initiated
19 more serious criminal proceedings initiated

January 12, 2026January 12, 2026 by Mark Handley

United Kingdom – trial scheduled in prosecution for supplying luxury art work to person connected with Russia

Further to our earlier post, it is being reported that the trial in the UK’s criminal prosecution the art gallery Hauser and Wirth, and shipping company, Artay Rauchwerger Solomons, has been scheduled for January 2028.

The companies are charged in relation to allegedly making a luxury good, a work of art, available to a person connected with Russia.

The next hearing is scheduled for 5 May 2026 at which the defendants will be able to enter their pleas.

January 12, 2026January 12, 2026 by Mark Handley

Latvia – prosecution for ammunition export to Russia

Latvia’s Prosecutor’s Office has issued a press release regarding bringing a criminal prosecution before the Riga City Court against an Estonian-Russian dual national for attempting to transport 10,000 items of ammunition into Russia.

The shipment was stopped at the Terekhov Customs crossing. As part of a search of the truck the bullets were found hidden within the driver’s cab of the truck.

January 12, 2026January 12, 2026 by Mark Handley

Romania – enforcement of travel ban on person designated under EU’s Global Human Rights sanctions

An individual included in the EU’s Global Human Rights sanctions list has been barred from entering Romania and deported.

The press reporting does not name the sanctioned individual, but the reporting indicates the person to have been an Israeli settler.

January 12, 2026January 12, 2026 by Mark Handley

Poland – individual charged for importing inflatable vessel from Belarus

Polish authorities have charged an individual after attempting to import an inflatable vessel into Poland from Belarus.

The individual is a Belarusian national, and the inflatable craft was identified by Polish customs at the Terespol border checkpoint.