November 2025 – European Sanctions Enforcement

November 28, 2025November 28, 2025 by Mark Handley

Finland – regulator’s audit findings on Nordea Bank’s sanctions compliance

Finland’s Financial Supervisory Authority has published the results of an “audit” on Nordea Bank in relation to the bank’s compliance with the asset freeze and export prohibition aspects of the EU’s Russian sanctions.

The result of the audit was a finding of a “very significant lack of information obtained and retained by the bank”, with a lack of updating on the information that was obtained. In addition, “shortcomings of great significance” were found in relation to customer due diligence, and a lack of adequate assessment of the risk of sanctions circumvention including payments that involved “a high risk country from the perspective of sanctions evasion”.

The announcement from the FIN-FSA does not indicate whether any further regulatory action will be taken.

My thanks to Louis Vargas of the Network for Financial Crime Prevention for informing on this published audit.

November 25, 2025November 25, 2025 by Mark Handley

Netherlands – trial commenced of shipbuilder for sanctioned exports to Russia

Further to our earlier post, the prosecution trial of Damen Shipping has commenced in the Netherlands.

The company has denied the allegations, which include that it falsified customs declarations to enable the export of 14 deck cranes to Russia during 2022 in breach of the EU’s sanctions.

Senior management have also been charged with sanctions offences.

The trial includes charges of bribery against Damen.

November 21, 2025November 21, 2025 by Mark Handley

Ireland – multiple cash seizures related to sanctions circumvention network

It is being reported that the Gardaí have conducted multiple cash seizures targetting a criminal network used for laundering money and sanctions circumvention.

The seizures value €1.36m and took place in multiple operations in Dublin and Leitrim in April and October this year.

It is alleged that the network “cleaned” the proceeds from ilegal activity and turned it into crypto currency. It is also alleged that the network provided sanctions circumvention services to the Russian state.

The Irish seizures were part of the broader Operation Destabilise which involved the UK’s National Crime Agency (see our post).

November 21, 2025 by Mark Handley

United Kingdom – National Crime Agency operation targetting sanctions circumvention network

The National Crime Agency has issued a press release relating to Operation Stabilise, which is targetted a criminal money laundering network that was also used to aid the circumvention of sanctions by Russia.

The NCA states that 45 money launderers have been arrested in the UK, and £25m seized in the UK, with international partners seizing $24m and €2.6m and arresting another 83 people.

The NCA notes the alleged involvement of networks called Smart and TGR and that a company linked to TGR’s head had purchased a 75% stake in a previously state-owned Kyrgyzstan bank – Keremet Bank – which was then used as part of the evasion/circumvention network.

The NCA reports a number of convictions for money laundering offences of individuals involved in the networks, and that the head of the Smart network is currently in custody in France.

The operation involved cooperation with the DEA, and FBI in the US, the Direction Centrale de la Police Judiciaire in France, the Jersey Police, Scottish Police, Finland’s National Bureau of Investigation, the Dutch National Police and Spanish law enforcement.

November 21, 2025November 25, 2025 by Mark Handley

Germany – raids in relation to export of hundreds of luxury cars to Russia

It is being reported that seven residential and commercial premises in the Steinfurt area were raided on 20 November by Customs officers from Essen, Münster and Osnabrück.

The raids relate to allegations that three individuals (aged 57, 32 and 27) were involved in the export of 346 luxury cars to Russia via third countries in breach of the EU’s sanctions.

The exports are said to have taken place between 2022 and 2024 and have totalled approximately €20m in value.

The report adds that assets (including real estate, cars and bank accounts) valued at €20m have been seized as part of the investigation.

November 20, 2025November 20, 2025 by Mark Handley

Sweden – Swedish Customs sanctions enforcement

The Swedish Police have issued a report on sanctions compliance in the country, concluding that trade flows to countries neighbouring Russia suggests Swedish involvement in the circumvention of the EU’s sanctions.

In relation to the work of Swedish customs, the report noted that in 2023 more than 200 export shipments were stopped, and that 3,000 export declarations in 2024 were “subject to special review measures”.

The press release to the report notes that “a handful of preliminary investigations [are] underway regarding sanctions violations at the Police Authority and at Swedish Customs”.

The report also highlights an earlier 2024 report by the Swedish Financial Supervisory Authority on the outcome of its review of the sanctions screening processes and methodologies of 19 banks operating in Sweden. The report noted that none of the banks assessed had good enough automatic screening in place, but that the larger banks were better at screening than the small and medium sized banks.

November 20, 2025November 20, 2025 by Mark Handley

Germany – arrest and raids related to machinery exports to Russia

German Customs has issued a press release reporting that the Customs Investigation Office and Public Prosecutor’s Office in Stuttgart have overseen raids on private and company premises relating to alleged machinery exports to Russia in breach of the EU’s sanctions.

Raids and searches were conducted on 10, 14 and 18 November and a 55-year old man has been arrested.

It is alleged that 5 machine tools were exported to Russia via third countries between October 2023 and December 2024. The value of the machinery is stated to have been €1.7m.

As well as raiding the exporting company, raids were also conducted on the premises of a freight forwarding company in Duisburg.

November 19, 2025 by Mark Handley

Germany – sanctions trial begins of individuals suspected of exporting €28m in luxury cars

The trial has commenced in Berlin of Evgeniya P., Wladimir K. and Ekaterina M. Only Evgeniya P. is before the court, the others are being tried in absentia.

The three are alleged to have exported 257 luxury cars to Russia in breach of the EU’s sanctions with a value of €28.2m.

The exports are reported to have been completed via Belarus, Kyrgyzstan, Kazakhstan or Turkey.

November 19, 2025 by Mark Handley

Latvia – company and individual convicted for organizing tour groups to Crimea

Latvia’s FIU has announced the successful appeal of an earlier acquittal resulting in the conviction of an individual and company for providing services related to the tourism sector in Crimea – i.e. organizing tourist trips to Crimea.

The case remains subject to further appeal.

The company was fined €10,500 and the individual sentenced to 100 hours of community service.

November 14, 2025November 14, 2025 by Mark Handley

United Kingdom – charges brought for making luxury art work available to person connected with Russia

As first reported in Global Investigations Review (here, behind a paywall), the UK’s Crown Prosecution Service has charged Hauser & Wirth (a Swiss company) that operates an art gallery in London, and logistics company Artay Rachweger Solomons each with a count of making a luxury good (i.e. a painting) available to a person connected with Russia in breach of the UK’s sanctions.

The person connected with Russia has not yet been named.

At a court hearing on 12 November, Artay Rauchwerger Solomons indicated that it intended to plead not guilty. Hauser & Wirth gave no indication.