2025 – European Sanctions Enforcement

June 18, 2025 by Mark Handley

Portugal – court judgments reveal ongoing Russian sanctions investigations for breaches of bank deposit cap

In a first for this blog, we can report on sanctions enforcement activity in Portugal.

Three judgments from the Lisbon Court of Appeal reveal ongoing investigations into alleged breaches of the EU’s regulation 833/2014.

The judgments are each the dismissal of appeals by anonymised persons who have had bank accounts frozen pending the outcome of the the criminal investigations in question. In each case the investigation appears to be focussed on alleged breaches of regulation 5b of 833/2014 and the €100,000 deposit cap first introduced in February 2022.

The judgments are from:

a) 24 May 2023: in this case it is alleged that a Russian national (named only as YS) transferred over €1.8m for the purchase of real estate in Portugal in February and June 2022. The judgment mentions that YS had been a senior manager within Gazprombank.

b) 6 February 2025: in this case it is alleged that two Russian nationals (named only as AA and BB) transferred $6m from accounts in Russia and Austria in February and October 2022, and another €4.7m in February and March 2022 There is also an allegation that the transfers related to Tatyana Golikova, who is a designated person under the EU’s sanctions.

c) 11 March 2025: in this case it is alleged that two Russian nationals residing in Russia (named only as AA and BB) transferred several hundred thousand euros to bank accounts in Portugal.

June 18, 2025June 18, 2025 by Mark Handley

Spain – arrests and detentions for the export of prohibited machinery to Russia

It is being reported that as part of a joint investigation by the General Information Commissariat, the Customs Surveillance Directorate of the Tax Agency, and the National Intelligence Centre that a raid was conducted in 10 June in the town of San Vicente del Raspeig in Alicante and three individuals have been arrested.

Following a hearing on Friday two of the arrested were imprisoned pending investigations and the third individual has been released.

It is alleged that an unnamed company exported machinery “mainly used in mass production industries, such as the automotive metallurgical industry, the aerospace industry, or also in the military industry“. It is alleged that the exports to Russia were conducted through third countries, that customs data was falsified, and that the end customer was a designated person under the EU’s sanctions.

The machinery is reported to have been valued at hundreds of thousands of euros.

June 11, 2025June 11, 2025 by Mark Handley

Sweden, Estonia and Lithuania: investigations opened into funding provided by Russian designated person

Further to our earlier post regarding an investigation in Latvia into the activities of the designated Russian state entity “Pravfond”, it has now been reported that a number of other investigations are ongoing in relation to this entity’s activities:

1) An investigation has been commenced in Sweden in relation to a school that had associations with Pravfond;

2) In Estonia a multiple investigations (by the criminal authorities and the bar association) have been opened in relation to lawyers who accepted funds from Pravfond; and

3) In Lithuania a criminal investigation has been opened (as well as one by the bar association) into lawyers who took funds from Pravfond.

June 11, 2025June 11, 2025 by Mark Handley

Netherlands – DNB issues instruction to trust office regarding sanctions compliance

The Nederlandsche Bank (DNB) has issued a press release relating to Erez Corporate Service B.V.

Erez was issued an “instruction” in June 2021 by the DNB in relation to the remediation of various compliance failings, including compliance with EU sanctions.

Erez has sought to challenge, and then appeal, this instruction, but those efforts have not been successful which is why the DNB are now publishing the details of the instruction.

June 11, 2025June 11, 2025 by Mark Handley

Estonia – conviction and 2-year sentence for making economic resources available to a designated person

Further to our earlier post, it has been reported that journalist Svetlana Burtseva has been convicted of breaches of the EU’s sanctions.

The offence was committed by making “economic resources” available to a designated person. The designated person was the sanctioned media outlet Rossiya Segodnya.

The “economic resources” were articles and photos written and taken by the journalist.

Ms Burtseva was sentenced to 2 years in jail for this offence.

Separately the same journalist was also convicted of treason and given a 4-year sentence for the treason offence.

June 3, 2025June 3, 2025 by Mark Handley

Latvia – 61 new criminal prosecutions for sanctions breaches commenced in 2025

In a previous post from April we reported on the 2024 annual report for Latvia’s FIU.

This included the statistic that 392 criminal proceedings had been commenced between 2022 and the end of 2024.

In an interview recently published with Global Investigations Review (behind a paywall), the head of Latvia’s National Customs Board has stated that Latvia has now brought a total of 453 criminal prosecutions.

This indicates that 61 new prosecutions have been brought so far in 2025.

June 3, 2025June 3, 2025 by Mark Handley

Germany – 41 criminal prosecutions for luxury car exports to Russia

The publication Business Insider has conducted a survey of the enforcement activity conducted by Prosecutors’ Offices across Germany in relation to the export of German cars, and published the results (behind a paywall).

A total of 14 different Prosecutors’ Offices confirmed that they have brought, or are bringing, criminal prosecutions in relation to the alleged export of luxury cars from Germany to Russia in breach of the EU’s sanctions.

The total number of prosecutions reported to date was 41.

May 28, 2025May 28, 2025 by Mark Handley

Latvia – sanctions investigation launched into activities of Russian state funder

It is being reported that the Latvia State Security Service has launched an investigation into the activities of the sanctioned entity “Pravfond”.

Pravfond is said to be a funding conduit by which the Russian state provides support for promoting Russia’s influence and interests abroad. It was designated under the EU’s Russian sanctioned in mid 2023.

The allegation is that it has continued to operate and provide funding despite being subject to the asset freeze.

May 27, 2025May 27, 2025 by Mark Handley

Latvia – investigation launched into Russian industrial exports

It is being reported that Latvia’s State Security Service (the VDD) has launched a criminal investigation into alleged exports of sanctioned machinery and equipment from the KLC Group to buyers in Russia via Kazakhstan and Kyrgyzstan.

The investigation follows the publication of a media investigation by The Insider.

The exports, said to be equipment used for military manufacturing, are said to be valued at $1.3m and to have included products from a number of western manufacturers.

May 27, 2025May 27, 2025 by Mark Handley

Netherlands – prison sentence for breaching Russian sanctions nearly doubled on appeal

Further to our earlier post that the Dutch Public Prosecution Service had brought an appeal seeking to extend an 18-month prison sentence for exporting sanctioned goods to Russia, the Court of Appeal in The Hague has now issued its judgment.

While most of the judgment relates to the issue of the amount of the “proceeds of crime” to be confiscated from the convicted defendant (reducing the level of confiscation from €72,697.71 to €71,582.95), the custodial sentence was also increased to detention for 1080 days, which is just under the 3 years sought by the Prosecution.