Mark Handley – Page 3 – European Sanctions Enforcement

October 9, 2025October 9, 2025 by Mark Handley

Germany – sentencing of five individuals convicted of Russian sanctions offences

Last month we posted regarding the conviction of five individuals for Russian trade sanctions offences by the Hamburg Regional Court.

It is being reported that the sentences have now been handed down.

Of the five individuals, one was given a custodial sentence of four and a half years, and two others were given custodial sentences of three years.

The final two defendants were given suspended sentences.

The offending concerned the shipment of electronic components valued at over EUR850,000 to Russia via third countries such as Hong Kong, China, Armenia and the UAE.

October 6, 2025October 6, 2025 by Mark Handley

France – seizure of Russian shadow fleet vessel and arrest of captain

It has been widely reported (e.g. here and here) that the French military boarded and seized control of an oil tanker reputed to to be part of the “shadow fleet”.

The vessel, the “Boracay” has been sanctioned by the EU and the UK. It is alleged that the crew failed to provide information to authorities on the nationality of the vessel or otherwise comply with orders.

It has now also been reported that the vessel has now continued on its voyage and the captain has been released.

October 6, 2025 by Mark Handley

Latvia – State Security Service seeks prosecution for providing project management services

Latvia’s State Security Service (the VDD) is seeking the prosecution of two Latvian nationals accused of providing project management services to Russian companies.

This is one of few known prosecutions for breaching the EU’s professional services prohibitions. It is alleged that the individuals were co-owners of a company through which the services were provided.

The investigation started in January of this year.

October 6, 2025October 6, 2025 by Mark Handley

Netherlands – arrest on suspicion of terrorist financing

In an investigation led by the Public Prosecutor’s Office, the Dutch FIOD last week conducted raids on two homes and arrested one individual suspected of transferring bitcoins valued at €5,000 to individuals who had joined terrorist organizations in breach of the Dutch Sanctiewet.

The transfers are said to have taken place between 2019 and 2020.

The FIOD Press release acknowledges the support of Europol in providing technical assistance and facilitating cooperation from other (unnamed) countries.

September 30, 2025September 30, 2025 by Mark Handley

United Kingdom – OFSI imposes £152,750 penalty for payments made to accounts held with designated banks

The UK’s Office of Financial Sanctions Implementation has today issued a Penalty Notice against Colorcon Limited, in relation to its Moscow branch office making 79 unlicensed payments to the company’s employees and suppliers who had accounts with designated Russian banks.

The payments were made between 23 March and 2 December 2022. The company self-reported to OFSI on 21 April 2023, but OFSI’s Notice states that the four month delay in reporting meant that the reporting was not “prompt”.

After assessing a range of aggravating and mitigating factors OFSI determined that the appropriate penalty should be £235,000 to which it applied a 35% discount for reporting (down from a 50% discount available for “prompt” reporting).

The Notice also points out that further payments were made while a “wind-down” general licence was in place, but that the reporting requirements under this general licence were not complied with. No fine was issued for this breach.

September 30, 2025September 30, 2025 by Mark Handley

Latvia – more than 600 criminal investigations into sanctions violations

In evidence before the European Parliament last week (timed at 11:29), and in a LinkedIn post today, Paulis Iljenkovs, the Deputy Head of Latvia’s FIU, has stated that Latvia currently has more than 600 criminal investigations (mostly into breaches of trade sanctions) ongoing into alleged Russian sanctions breaches.

September 30, 2025September 30, 2025 by Mark Handley

Spain – updates on investigation into alleged exports of prohibited chemicals to Russia

Further to our earlier post from February 2025, regarding the Spanish authorities seizure of 13,000 tons of prohibited chemicals from being exported to Russia, it is now being reported by the OCCRP that the chemical in question was N-Methyl-2-pyrrolidone used in a range of manufacturing.

While it is reported that the Audiencia Nacional has confirmed that as yet no one has been charged, it has been confirmed that nine individuals are currently under investigation as suspects including Maria Oleinikova and her son and daughter Vyacheslav and Irina and the German national Werner Scharlau.

Maria Oleinikova declined to comment on the story due to the ongoing proceedings.

September 30, 2025September 30, 2025 by Mark Handley

Finland – 26 investigations into breaches of trade sanctions started in 2025

Further to our earlier post regarding Finland’s hundreds of sanctions investigations, we are pleased to acknowledge the help of Finnish Customs in supplying newly-updated information on the investigations so far commenced for breaches of the EU’s trade sanctions. These figures do not include investigations relating to financial sanctions.

While information on the penalties/sentences imposed is not available it can be noted that:

Petty regulation offences are punishable only by fines;
Regulation offences are punishable by fine or imprisonment for a maximum of 2 years; and
Aggravated regulation offences are punishable by imprisonment of at least 4 months and not more than 4 years.

The updated figures include concluded enforcement actions up to 17 September 2025, and include some revisions to the previously supplied data for the previous years.

As previously noted the reduction in the punishment of petty regulation offences between 2023 and 2024 is most likely to be attributed to the closures of the land crossings into Russia.

Year	Petty Regulation Offence	Regulation Offence	Aggravated Regulation Offence	Total
2022	104	163	39	306
2023	353	81	58	492
2024	5	59	35	99
2025	2	15	9	26
Total	464	318	141	923

September 30, 2025September 30, 2025 by Mark Handley

Italy – stock exchange regulator investigates luxury goods manufacturer

It has been reported (here, behind a paywall), that CONSOB (the Italian stock exchange regulator) has been investigating comments made by luxury goods manufacturer Brunello Cucinelli in relation to the company’s compliance with the EU’s Russian sanctions.

Last week several short sellers of Brunello Cucinelli stock issued reports alleging that the company’s stores remained open in Russia and continued to sell prohibited luxury goods. Despite denials from the company, these reports led to a sharp reduction in the price of the shares and trading in the stock was suspended.

The CONSOB investigation is primarily focussed on the question of whether the company has misled the market in its public comments and denials.

September 24, 2025September 24, 2025 by Mark Handley

Poland – 20 people detained for alleged luxury car exports to Russia and Belarus

Poland’s Central Bureau of Investigation of the Police has issued a press release relating to the arrest of 20 people for alleged involvement in a scheme to export of approximately 600 luxury cars to Russia and Belarus in breach of the EU’s sanctions.

The scheme is said to have involved a sequence of sales within the EU, followed by sales to customers in third countries such as Kazakhstan and Azerbaijan, followed by a further transfer to Belarusia or Russia.

Several of the defendants are being detained in custody while the investigation continues.

More than PLN 10m in bank accounts have been frozen as part of the investigation.