Mark Handley – Page 3 – European Sanctions Enforcement

August 24, 2026August 24, 2026 by Mark Handley

Germany – update on confiscation proceedings relating to the crude cargo of detained tanker, the Eventin

Further to our earlier post relating to the detention of the tanker Eventin by Germany in January 2025, press reporting has provided an update on the progress of the efforts by German Customs to confiscate and sell the 99,000 metric tonnes of crude on board.

It appears that Customs have decided to discontinue efforts to expedite the confiscation, with the issues relating to the confiscation, of whether any sanctions offence was committed, and whether the vessel, which was suffering engine trouble, was entitled to sail into German waters to obtain safe refuge, will be determined in the respective proceedings brought by the ship’s owner, Laliya Shipping Corp in March and April of this year.

August 24, 2026August 24, 2026 by Mark Handley

UK and Ireland – TikTok self reports possible sanctions breaches

It has been reported, here (behind a paywall), that TikTok Information Technologies UK Limited, has self-reported potential breaches of sanctions both to the UK’s Office of Financial Sanctions Implementation, and to Ireland’s Central Bank of Ireland, as well as to other unnamed regulators.

The information on the self-reporting comes from the most-recently filed company accounts, available from Companies House in England:

No other information is available on the sanctions regime, or regimes, involved, the nature of the potential breaches, or the progress in any regulatory investigations since April.

August 11, 2026August 11, 2026 by Mark Handley

Austria – suspected exports of military manufacturing equipment lead to raids and arrest

Austria’s Interior Ministry has issued a press release detailing on ongoing investigation and prosecution into a procurement network for the Russian arms industry.

The goods were CNC machines and related tools for metal processing. The suspected exports involved a network of companies in Turkey, the United Arab Emirates, Hong Kong, Belarus, Kyrgyzstan, South Korea, Poland and Lithuania.

End-user certificates were also forged to mask that the real customer was Russia’s state-owned arms manufacturer ROSTEC. The goods are said to have been used in the production of engines for missiles and fighter jets.

Four properties were raided in August 2025 revealing evidence of exports valued at €3.3 million mostly shipped via Hong Kong and Turkey.

Evidence of continuing intentions to export led to the arrest on 13 May 2026 of a Belarussian national who was the managing director and co-shareholder of the unnamed company. He remains in custody.

August 3, 2026August 3, 2026 by Mark Handley

EU – another sanctioned tanker – the Toa Payoh – boarded in the Mediterranean

Further to our earlier post, it is being reported that, on Sunday 2 August, the EU’s operation EUNAVFOR MED Irini has boarded another tanker, the Toa Payoh, off Sicily. The vessel was sailing from Benin to Istanbul.

The boarding was to determine and investigate the flag status of the vessel which was claiming to have recently switched to a Cameroonian flag.

The vessel was not seized or detained as part of the operation.

August 3, 2026August 3, 2026 by Mark Handley

United Kingdom – two fines for military export control breaches

On 27 July, the UK’s HM Revenue and Customs issued a “Notice to Exporters” relating to two companies fined £216,530.30 and £20,889.15 respectively.

The companies were not named.

The conduct was not described in any detail and only said to “relate to unlicensed exports of military-listed goods and related activity prohibited by The Export Control Order 2008 and contrary to The Customs and Excise Management Act 1979”.

The details of why and how these companies were able to secure a resolution via a compound penalty were also not provided, although the Notice says in general terms:

“Compound settlements may be offered where an exporter has:

voluntarily told HMRC about sanctions or export control breaches, and
committed a breach that was inadvertent or due to weaknesses in internal controls”.

July 30, 2026July 30, 2026 by Mark Handley

EU – sanctioned oil tanker boarded in Mediterranean

It is being reported that on 20 July, the EU’s Mediterranean naval taskforce IRINI boarded the Turkish-owned oil tanker, the South Star, in order to assess and investigate its flag status. Under a different name the vessel had been designated by both the EU and the UK in 2025.

The report states that there was uncertainty over the vessel’s flag status as between Cameroon and Equatorial Guinea.

The vessel was allowed to proceed after the boarding and inspection.

The same reporting refers to IRINI’s published information which says that it had conducted three earlier flag verification boardings during the month of June.

July 30, 2026July 30, 2026 by Mark Handley

United Kingdom – £6.4m fine for strategic export control failures

Further to our earlier post reporting on the UK’s investigation into Airbus, HMRC has today issued a Notice to Exporters that Airbus Operations Limited (AOL) has entered into a compound settlement with HMRC under which it will pay a fine of £6,409,388 for offences under The Export Control Order 2008.

This is the largest fine imposed by HMRC under the compound settlement regime, and is another example of the new practice of sometimes naming companies that enter into such settlements.

The offences do not relate to sanctions but to the UK’s strategic export controls regime.

The breaches took place “over a sustained period” before November 2022 and were self-reported by AOL which cooperated with the investigation and has implemented remediation.

The breaches are described in only general terms as follows:

Article 29(2)(a-g) on multiple occasions for failing to keep accurate records of transfers of controlled technology as per the conditions of three of their Open General Export Licences (OGELs)
Article 29(3) on multiple occasions for failing to keep registers in relation to their OGELs
Article 29(2)(i) on multiple occasions for failing to keep accurate records contrary to the conditions of one of their OGELs
a Standard Individual Export Licence (SIEL) on one occasion, relating to a failure of licence conditions

July 20, 2026July 20, 2026 by Mark Handley

United Kingdom – sanctions enforcement statistics for HMRC in 2025/26

The UK’s HMRC has released enforcement statistics for 2025 and the first part of 2026 in a “Technical Note”:

22 criminal investigations with three charges and two (at the time of the release of the Note) pending trial;
58 seizures of sanctioned goods
1 compound penalty of £1,160,725.67 (see our previous post);
29 self-disclosures, with these being resolved as follows:
- 18 warning letters;
- 7 no further action letters;
- 1 compound penalty;
- 3 cases remain unresolved.

By way of cooperation with the Office of Trade Sanctions Implementation, there were 44 referrals to HMRC in 2025/2026, with 10 resulting in no further action, 13 relating to already-ongoing investigations; and 21 still under review.

July 20, 2026July 20, 2026 by Mark Handley

United Kingdom – charges dismissed against art gallery and transporter

Further to our earlier post, on 9 July, the charges against the art gallery Hauser & Wirth, and art logistics company Artay Rauchweger were dismissed on the basis of a pre-trial application. The dismissal was first reported by GIR behind a paywall.

The charges related to an allegation that the gallery sold a painting to a “person connected with Russia”. The relevant statutory definition (in regulation 19A(2)(a) of the UK’s Russian sanctions regulations), is that the person must be either “ordinarily resident in Russia” or “located in Russia”. The focus for the court was the first test.

The judge held that a properly directed jury would be unable to find that there was sufficient evidence that the buyer of the artwork was “ordinarily resident” in Russia at the time of the sale in July and August 2022.

The prosecution produced evidence of a continuing connection to Russia, but the judge is reported to have held that “the statutory test is not one of continuing connection, nationality or association, but ordinary residence”.

July 20, 2026July 20, 2026 by Mark Handley

Poland – investigation into timber imports instigated by the EPPO

The European Public Prosecutor’s Office (EPPO) has issued a press release relating to an investigation in Poland into suspected Russian sanctions breaches.

The Municipal Police Headquarters in Katowice and the Silesian Customs and Tax Office – Częstochowa Branch, have responded to a request for assistance from the European Public Prosecutor’s Office (EPPO) in conducting an investigation related to customs and VAT fraud, as well as sanctions breaches, arising from the importation of birch wood into Poland between October 2023 and April 2025.

The company being investigated is alleged to have falsely declared the origin of the timber as Kazakhstan, when it is alleged to have actually originated from Russia.