2025 – European Sanctions Enforcement

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 2, 2026 by Mark Handley

Poland – 5 arrested on suspicion of importing sanctioned Russian and Belarusian timber

Poland’s Customs and Tax Service has conducted raids and arrested five individuals suspected of importing Russian and Belarusian birch plywood under falsified papers to make it appear that the timber was of Kazakh or Turkish origin.

The five individuals have been named as:

Franciszek B. (64 years old, Polish citizen)

Marian K. (48 years old, Polish citizen)

Piotr K. (56 years old, Polish citizen)

Aleksander P. (43 years old, Russian citizen) and

Sergey M. (57 years old, Russian citizen).

The imports are alleged to have taken place between 2022 and 2024.

The investigation was aided by materials from OLAF (the European Anti-Fraud Office) and from the response to a mutual legal assistance request provided by Kazakhstan.

The suspects have all been charged but have been release pending trial.

January 2, 2026January 2, 2026 by Mark Handley

Germany – €10 million payment to settle sanctions investigation into Usmanov

Prosecutors in Germany have settled their investigation and prosecution of Alisher Usmanov for suspected breaches of EU sanctions.

The settlement involves a payment of €10 million but no admission of liability.

The investigation related to allegations of payments made by or on behalf Usmanov, a designated person, in relation the provision of security for two properties in Germany.

December 23, 2025 by Mark Handley

Lithuania – raids as part of investigation into sanctioned exports to Russia and Belarus

It is being reported (here and here) that Lithuania’s Financial Crime Investigation Service and the State Security Department, with coordinating assistance from the European Public Prosecutor’s Office, are undertaking an investigation into suspected breaches of the EU’s Russian and Belarus sanctions by Lithuanian, Russian and Belarus individuals.

It is alleged that those involved forged documents to obtain funding from the EU Space Agency, and that the money was then used (with other funds) by a company incorporated in Lithuania to obtain and export microchips, semiconductors, navigation systems, and other technical devices to Russia and Belarus.

In total 10 raids were conducted, and 5 individuals and one company are under investigation.

December 23, 2025December 23, 2025 by Mark Handley

Sweden – Customs board distressed Russian vessel in Swedish waters

After a Russian vessel had engine trouble and entered Swedish territorial waters, Swedish Customs boarded the vessel and commenced an investigation into whether possible sanctions or export control offences may have been committed.

The vessel, the Adler, is designated under EU sanctions, and the owner sanctioned by the US. It is reported that the cargo included arms and military equipment.

It is now being reported that the vessel has been allowed to depart Swedish waters, after the Prosecutor’s Office declined to open a criminal investigation, on the basis that there was no intent to being the vessel or its goods into Sweden.

December 23, 2025December 23, 2025 by Mark Handley

Latvia – raids and arrest for alleged sanctions breaches

It is being reported that Latvia’s State Security Service conducted a number of raids, and arrested an individual suspected of breaching the EU’s sanctions against Russia.

It is being reported that the individual is Viktors Guščins, who is alleged to have provided an economic resource to a designated person in the form of publications and propaganda material.

December 23, 2025December 23, 2025 by Mark Handley

France – Lafarge sanctions trial ends with verdict due in April 2026

After a six-week trial, verdict in the Lafarge prosecution is now expected on 13 April 2026.

The Anti-Terrorism Prosecutor’s Office is seeking a fine of €1.125 million, as well as a fine of €4.57 million that is directly related to the alleged breaches of EU sanctions.

The prosecution is also seeking lengthy jail terms for the eight individual defendants of between 18 months and 8 years, including 6 years for the former CEO, as well as a €225,000 fine and a 10-year ban on serving in any management position in a company.

December 16, 2025December 16, 2025 by Mark Handley

United Kingdom – OTSI provides enforcement update

The Office of Trade Sanctions Implementation has published a report on its first year of operations.

In relation to enforcement it says that it has “a number of investigations underway”, and that it has “referred a significant number of cases to HMRC and other government partners”.

No other information is provided, although further information is promised in the 2026 Annual Report.

December 16, 2025December 16, 2025 by Mark Handley

Germany – report that there are 6,000 criminal proceedings for Russian and Belarus sanctions breaches ongoing

It is being reported in an article published in trans.info that the German authorities currently have approximately 6000 criminal proceedings for sanctions offences that are ongoing.

This number is said to be specific to the EU’s Russian and Belarusian sanctions regimes.

No further information is provided on the status of the cases.

December 8, 2025December 8, 2025 by Mark Handley

Latvia – prosecution for providing professional services to Russian companies

Latvia’s VDD has asked the Prosecution Office to commence a prosecution of a latvian national for providing prohibited services to companies in Russia.

As per the press release: “DD found that the Latvian citizen had entered into employment contracts with multiple companies registered in Russia, where the person held the positions of general director and director and directly gave prohibited consultations on economic activities, management and taxation”.

This prosecution is one of several recently launched in Latvia (see our earlier post) in relation to alleged breaches of the prohibitions contained in regulation 5n of 833/2014.