August 2025 – European Sanctions Enforcement

August 28, 2025 by Mark Handley

European Sanctions Enforcement – round up of a busy summer

It has been a busy summer on the enforcement front but the blur of repeated individual announcements can, ironically, mask the scale, breadth and scope of the current level of enforcement activity taking place across Europe.

So to help we have put all the posts since June into one place.

Collectively these paint a picture of enforcement in 19 different countries (20 if you want to count Guernsey separately). Of these 16 are EU member states with enforcement also seen in the UK, Switzerland and Iceland.

There have been 7 criminal convictions generating 19.5 years of jail time, and fines and confiscations of over €9m , as well as multiple raids of companies and homes (in Bulgaria, Denmark, Estonia, Germany, Italy, Latvia, Lithuania, the Netherlands, Portugal and Spain), not to mention the announcement of multiple arrests and investigations. And this is just what is public.

For those who remember what enforcement used to look like before 2022, activity like this is fairly extraordinary.

Bulgaria

23 August: raids in conjunction with Lithuanian and Portuguese authorities on exporter
13 August: raids on alleged arms exporter to Russia
4 August: raids in conjunction with German authorities on machine tool manufacturer

Czechia

30 June: investigations launched into 12 companies suspected of sanctioned exports

Denmark

23 July: raids on paint manufacturing company and company and management charged

Estonia

Finland

France

1 July: ACPR imposes fine of €600,000 for sanctions compliance failings

Germany

Greece

15 July: investigation made public into alleged imports of sanctioned timber

Guernsey

4 August: licence revoked and fines of £210,000 imposed on financial services firm and individual

Iceland

13 August: first fine (c. €153,000) on a bank for sanctions compliance failings

Italy

30 June: Italian police raid premises related to Iran’s military support for Russia

Latvia

Lithuania

Malta

8 July: two fines for sanctions violations made public

Netherlands

13 August: professional football team barred from leagues due to risk that it is owned or controlled by a designated person
10 July: person sentenced to 3 years in jail for sharing technology
10 July: confiscation of €1,013,956.00 as profits from provision of prohibited services
4 July: raids and arrests for company alleged to be supplier to the shadow fleet
11 June: DNB issues instruction to trust offence for sanctions compliance failings

Portugal

Spain

Sweden

11 June: investigations into suspected use of funds by designated person

Switzerland

25 August: publication of 13 Administrative Penalties for sanctions offences

United Kingdom

August 27, 2025August 27, 2025 by Mark Handley

Latvia – investigations into sanctioned Belarusian urea imports

It is being reported that the Latvian authorities have been conducting multiple investigations into suspected imports of urea from Belarus in breach of the EU’s sanctions.

The investigations are reported to be focussed on four Latvian companies and were commenced in July.

After a referral from the Customs Administration the VID Tax and Customs Police Department initially declined to prosecute, but that decision is now the subject of an appeal brought by the Customs Administration and Latvia’s FIU.

August 27, 2025August 27, 2025 by Mark Handley

Estonia – prison sentence for offences including the attempted export of luxury goods

It is being reported that the Tartu Country Court yesterday convicted Erna Moisejeva of a range of offences including the multiple attempted exports of luxury goods to Russia n breach of the EU’s sanctions.

She was also convicted of espionage and supplying information to the FSB.

Moisejeva was sentenced to 3 years’ jail and ordered to pay court costs of €3140.

The judgment remains subject to appeal.

August 25, 2025August 25, 2025 by Mark Handley

Estonia – prosecution of lawyer for sanctions offences

Further to our earlier post, the Estonian authorities have decided to prosecute an Estonian lawyer for alleged breaches of sanctions. The Prosecutor’s Press Release states that attorney Urmas Simon has been charged with making an economic resource available to the designated person Pravfond, in the form of legal services to a third party paid for by Pravfond. Mr Simon is also charged in relation to taking payment from the sanctioned entity.

August 25, 2025August 25, 2025 by Mark Handley

UK – suspended custodial sentence for refusal by designated person to provide financial information

Further to our earlier post, sentence has been passed in relation to the conviction of Aozma Sultana for refusing the provide financial information to OFSI despite repeated requests. The judge noted that the information had still not been provided.

The judge stated that the starting point for such an offence should be a custodial sentence of 15 weeks. Evidence was presented, however, that Aozma Sultana was the primary care provider for her 38-year-old wheelchair-bound brother, who suffers from cerebral palsy.

On that basis the judge sentenced to Aozma Sultana to 10 weeks’ imprisonment, suspended for 12 months. The court also ordered Sultana to complete 50 hours of unpaid work and 25 days of rehabilitation.

August 25, 2025 by Mark Handley

Switzerland – 13 administrative penalties for sanctions offences (March 2024 to July 2025)

Further to our earlier posts publishing the Administrative Penalties imposed by Switzerland’s SECO, we are providing details of a further 13 penalties imposed.

The blog is grateful to SECO for providing anonymised copies of the penalty notices.

16. Final administrative decision, dated 18 March 2024 (I.36)

Notice.

SECO was notified by Customs at Geneva Airport following the seizure of weapon parts imported from Russia.

SECO pend an investigation and determined that the parts were not for weapons intended for hunting or sport.

The importer was individual who had ordered the goods from a Russian manufacturer. This is the first instance of a fine imposed on individual by SECO for Russian sanctions breaches.

SECO assessed the breach as negligent rather than intentional, and imposed a fine of CHF 300, plus costs of CHF 360. The imported items were confiscated.

17. Administrative penalty dated 18 March 2024 (I.72)

Notice.

This notice relates to the attempted export of 4 leather bags each valued at €370, with a total value of €1,480.

The goods were returned to seller.

The notice states that this was a repeat infraction by the company in question, with it having been the subject of proceedings that were dismissed on 19 December 2022.

The export was said to be result of human error during a busy time and SECO took the view that the breach was negligent and not intentional.

The company was fined CHF 1000 with costs of CHF 560.

18. Administrative penalty dated 23 May 2024 (I.75)

Notice.

SECO’s proceedings were commenced on 8 January 2024 and relates to an attempted export by a Russian national to Russia of luxury jewelry valued at CHF 14,100 and seized at Zurich airport.

The jewelry had been sold to that person with a VAT exemption on the basis that the person was a tourist. The invoice issued by the selling company referred to the individual as resident in the Russian Federation.

SECO accepted that the breach by the seller was negligent and not intentional, and imposed a fine of CHF 4,500, and costs of CHF 1260.

The Notice contains no indication of confiscation of the proceeds from the sale, but will be of interest for sellers of luxury goods to Russian nationals, especially where there is a reason to think that the goods would be taken to Russia.

19. Administrative penalty dated 23 May 2024 (I.91)

Notice.

The investigation was started on 27 February 2024, following the shipment of 12 electric heating resistors valued at CHF 6,400 bound for Russia and stopped at Zurich airport.

SECO determined that the breach was not intentional, but a result of a negligent failure to understand which products codes were prohibited. The company was noted as having cooperated.

A fine of CHF 1,000 was imposed plus CHF 1,260 in costs.

20. Administrative penalty dated 5 June 2024 (I.80)

Notice.

This is a short notice with substantial redactions. It relates to the attempted export of flowmeters and electric motors to Russia of uncertain value.

The company was fined CHF 700 plus costs of CHF 40.

21. Administrative penalty dated 17 June 2024 (I.84)

Notice.

This Notice relates to the attempted export of prohibited goods to Russia, being spare parts for machine tools.

The goods were not confiscated but were released back to the exporter.

The company was fined CHF 500, plus costs of CHF 650.

22. Administrative penalty dated 9 September 2024 (I.90)

Notice.

This Notice relates to prohibited imports of plastic packaging from Russia valued at c. €3,536. The goods had been donated to assist with medical research and had not been purchased.

SECO took the view the breach was negligent and not intentional and imposed a fine of CHF 500 plus costs of CHF 580.

23. Administrative penalty dated 9 October 2024 (I.94)

Notice.

This relates to an attempted export referred by Swiss Customs to SECO. Seven different categories of goods were involved, six of which were prohibited from export. The goods were valued at more than CHF 15,000.

The lawful export was allowed to proceed and the others goods were all returned to the exporter rather than being confiscated.

The company had conducted google searches to determine whether the goods were subject to prohibitions, but these provided faulty answers. SECO determined the breach was negligent and not intentional and so fined the company CHF 5,000, plus costs of CHF 1,460.

24. Administrative penalty dated 18 December 2024 (I.101)

Notice.

This Notice relates to an attempted export of satellite parts to Ukraine without a licence. SECO approved a retrospective licence application to allow the export to proceed but imposed a fine of CHF 1000 plus CHF 20 in costs.

Previously SECO had taken the view that it was not permissible to apply for retrospective licences.

25. Administrative penalty dated 5 November 2024 (I.93)

Notice.

The Notice relates to the importation of prohibited goods valued at €22,650 reported to SECO by Swiss Customs. SECO commenced its investigation in July 2024. The goods in question were an electrical cabinet with customs code 8537.1000.

The importer had obtained erroneous advice that the goods had a non-prohibited customs code.

SECO prosecuted for negligent breach and imposed a fined CHF 5,000 plus CHF 850 in costs.

26. Administrative penalty dated 9 May 2025 (I.109)

Notice.

This Notice relates to an import shipment from Russia seized at Basel Airport and referred to SECO consisting of clothing valued at CHF 28,689. These were imports prohibited under Switzerland’s Russian sanctions.

SECO accepted evidence from senior company representatives that they were unaware of the existence of the prohibitions, and so SECO proceeded on the basis of a negligence, rather than an intentional, breach.

A fine of CHF 2000 plus CHF 300 in costs was imposed.

27. Administrative penalty dated 11 June 2025 (I.110)

Notice.

This Notice relates to the attempted export to Russia of goods of uncertain value with classification codes 8544.4200 (insulated cables), 3917.4000 (plastic fittings) and 8481.8000 (valves and other fittings). The exporter is said to have applied for, and been granted, a licence after the event.

The company was fined CHF 800 plus CHF 20 in costs.

28. Administrative penalty dated 9 July 2025 (I. 114)

Notice.

This Notice relates to the seizure of goods valued at CHF 11,739 bound for export to Russia, with no licence having been sought, and with product code 9027.5000 (instruments for physical or chemical analysis).

The company was fined CHF 1000 with CHF 20 in costs. The fine is described as having been for the failure to obtain a licence, and not for the attempted unlicensed export itself.

The Notice does not indicate whether the goods were returned to the exporter or confiscated.

August 25, 2025August 25, 2025 by Mark Handley

Lithuania – Customs raids and arrests for sanctioned exports in conjunction with raids in Portugal and Bulgaria

On Saturday Lithuania’s Customs issued a press release announcing raids on a company based in Kaunas, and associated residential premises, with 11 people (employees, company managers, as well as drivers) detained and a dozen tons of equipment (valued at around €2 million) seized.

It is alleged the company was exporting to Russia via Bulgaria and Turkey based on a fictitious customer in Portugal. Contemporaneous raids were conducted in Bulgaria to seize a shipment that had already left Lithuania, and in Portugal at the premises of the Portuguese customer.

The operation was coordinated by Eurojust and Europol and with assistance from the Portuguese authorities.

The exports are described as “water treatment equipment (dosing stations, large industrial water filters (osmosis), etc.) and their components (various pumps, filters, membranes)”. The press release adds that the products were specifically designed for the Russian customer.

August 13, 2025August 13, 2025 by Mark Handley

Iceland – bank fined for sanctions compliance failings

This post is catching up on a previously-missed fine issued on 9 May 2025, and first brought to wider attention by Global Investigations Review.

The Financial Supervisory Authority of Iceland’s Central Bank has fined Fossa fjárfestingarbanka hf for compliance failings including sanctions compliance failings as well as anti-money laundering.

The press release is here, and the more detailed note of the findings and fine is here.

In relation to sanctions the failings were a lack of adequate screening, and a lack of ongoing screening with most files sampled having been screened at onboarding but not subsequently. It is not alleged that these failings permitted breaches of sanctions to take place.

The bank was fined ISK 22,000,000 (approximately €153,000).

Iceland largely adopts the EU’s various sanctions regimes. This is the first example of enforcement in Iceland included in this blog.

August 13, 2025August 13, 2025 by Mark Handley

Bulgaria – raids on companies suspected of arms exports to Russia

It is being reported that the National Investigation Service of Bulgaria has conducted multiple raids in Sofia and elsewhere in relation to alleged arms sales to Russia.

The raids are being conducted after information shared by Ukraine’s National Anti-Corruption Bureau.

A press release from the Prosecutor’s Office refers to raids on business and residential properties, relating to multiple companies. The only company named as the subject of the raids in the press reporting is Sage Consultants AD.

The raids were also conducted with officers from the General Directorate for Combating Organized Crime (GDCOC) and the General Directorate Gendarmerie, Special Operations and Counterterrorism.

August 13, 2025August 13, 2025 by Mark Handley

Netherlands – sanctions lead to professional football club being barred from Dutch leagues

The professional football club Vitesse Arnhem has been barred from the Dutch football leagues.

Further to our earlier post, the Dutch authorities and the Dutch football league have been investigating allegations that Roman Abramovich owns or controls the football club.

The football league determined, on the basis of various breaches of league rules, including the sanctions risks created by Mr Abramovich’s ownership or control of the club, to bar the club from participation in the Dutch second division.

The club sought to appeal that decision, and in a published judgment, the District Court in Midden-Nederland, has rejected that appeal.

The government’s investigation remains ongoing.