2025 – European Sanctions Enforcement

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.

August 13, 2025August 13, 2025 by Mark Handley

Estonia – Russian diplomat expelled, in part for sanctions violations

The Foreign Ministry of Estonia has issued a press release stating that it has declared a Russian diplomat persona non grata requiring the diplomat to leave Estonia.

The press release stated, in part:

“The diplomat in question has been directly and actively involved in undermining the constitutional order and legal system of Estonia, as well as in dividing Estonian society, contributing to the crimes against the state, including several offences related to sanctions violations. At present, one citizen of the Republic of Estonia has been convicted for carrying out these crimes.”

No further information is yet avail;able on the specifics of the alleged violations, or of the conviction of the Estonian national.

August 4, 2025August 4, 2025 by Mark Handley

Germany and Bulgaria – raids at German manufacturer with three charged with sanctions offences

Last week more than 140 officers from the Munich Customs Investigation Office and the Munich I Public Prosecutor’s Office conducted raids on several premises in Munich and Baden Württemberg.

The subject of the raids was a machine tool manufacturer suspected of exporting 20 machines valued at more than €5.5m to Russia in breach of the EU’s sanctions.

It has subsequently been reported that the company was Spinner GmbH.

It has also now been reported that three individuals have been charged with sanctions offences. They have not been named.

The press release from the Munich Public Prosecutor’s Office also stated that the Bulgarian authorities conducted contemporaneous raids at premises in Bulgaria with support and coordination from Eurojust.

August 4, 2025August 4, 2025 by Mark Handley

Guernsey – licence revoked and fines imposed on financial services firm and individual

The Guernsey Financial Services Commission has issued a release regarding the imposition of several fines and the revocation of regulatory authorisations for a firm and an individual.

The firm ITI Trade Ltd was fined £175,000, and Mr Alexi Filatov was personally fined £35,000.

An order has been issued preventing Mr Filatov from holding a regulated position for 2 years and 10 months.

ITI Trade Ltd agreed to surrender its licence.

The compliance failings were first identified by the Commission in 2019, and the firm undertook (or purported to undertake) various remediation programmes (the results of which were doctored for the purpose of submissions to the Commission), before the Royal Court appointed Administration Managers over the firm in July 2022.

The failings relate to a lack of sanctions and AML compliance, due diligence and screening with the Guernsey entity “used to appear to provide investment services from Guernsey, when in reality much of the business was conducted in Russia”.

August 4, 2025August 4, 2025 by Mark Handley

Estonia – sanctioned Russian timber enforcement

Estonia’s Customs has issued information on its current enforcement activity in relation to sanctioned Russian timber.

While noting the use of Kazakhstan, China and Georgia as prominent third countries used for attempts to import Russian timber, Estonian Customs notes:

618 inspections conducted on imported timber;
79 shipments refused entry to Estonia;
100 proceedings based on a fraudulent origin of the timber commenced; and
23 sanctions violations identified.

The release does not identify the outcomes of the 23 identified violations.

August 4, 2025August 4, 2025 by Mark Handley

United Kingdom – OFSI imposes a fine of £300,000 for breach of EU Russian sanctions

OFSI has published a Penalty Notice fining a UK company Markom Management Limited (“MML”) £300,000 for breaches of The Ukraine (European Union Financial Sanctions) (No.2) Regulations 2014.

The fine was for issuing a payment instruction to return an overpayment of £416,590.92 to a Russian bank account belonging to a designated person.

The fine was initially set at £400,000, but was reduced through the ministerial review process.

This penalty is noteworthy for a number of reasons:

This enforcement action dates from events in 2018. While underscoring the slowness of OFSI’s enforcement steps it also reinforces the lack of a limitation period for the UK’s sanctions, and the fact that the UK continues to enforce the EU sanctions that were in place before Brexit.
The self-reporting by MML was considered insufficient to trigger a discount to the imposed penalty.
The conduct that warranted the penalty was a person in the UK sending a payment instruction to a bank in Russia to transfer funds to another bank in Russia. This is a reminder of the broad reach of the UK’s criminal jurisdiction when it comes to communications sent in or out of the jurisdiction. This penalty notice sits uneasily alongside the recent civil decision in Celestial Aviation Trading Ireland Ltd & Ors v Volga-Dnper Logistics BV [2025] EWHC 1156 (Comm).

July 23, 2025July 23, 2025 by Mark Handley

Denmark – raids, arrests and individuals and company charged in Russian sanctions prosecution

After press reporting had published allegations that the Danish paint company Flügger may have been continuing to trade with Russian customers via third countries in breach of EU sanctions, on 26 June the National Unit for Special Crime (NSK) conducted raids on the business premises of Flügger, and the homes of the company’s CEO and CFO.

The CEO and CFO were arrested as part of the raids, and have both been charged with sanctions offences as has the company itself.

The company has issued a press release confirming the investigation and stating that it has been deceived by distributors in Kazakhstan, Estonia, Azerbaijan and Kyrgyzstan.

July 22, 2025July 22, 2025 by Mark Handley

Estonia – lengthy custodial sentence for sanctions offences

Estonia’s Office of the Prosecutor has issued a press release regarding an agreed settlement with Pavel Kapustin convicting him of sanctions offences as well as espionage and supplying false information.

The man was sentenced to 6.5 years’ jail and assets valued at €90,000 were confiscated. The press release does not break down the sentence by offence.

The man took orders for luxury goods from Russian customers and arranged for their transport to Russia in breach of the EU’s sanctions.

This is the sixth custodial sentence handed down in Estonia for sanctions offences so far this year.