2025 – European Sanctions Enforcement

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.

June 23, 2026June 23, 2026 by Mark Handley

Lithuania – sanctions enforcement statistics and €6.2m in fines for 2025

Lithuania’s Financial Crimes Investigation Service has issued a summary of its work for 2025, as well as a more detailed report (see pages 45-46) that includes the following:

232 suspicious activity reports from financial institutions related to suspected breaches or circumvention of sanctions;
77 of these were reported to other competent bodies in Lithuania or in other EU member states;
45 inspections from the International Sanctions Implementation Commission;
€6,236,375.46m in fines for 2025 across 12 cases;
In addition:
- in 2025, 27 cases were dealt with administratively with fines in these minor cases totalling more than €32,150
- in 2024, 19 cases were dealt with administratively with fines totalling €28,000
- in 2023, 12 cases were dealt with administratively (the value of the fines is not given)

The report also notes that 1 of the cases related to public procurement, 1 to the failure to provide information, 5 to circumvention, and 20 to the use of a bank designated by the EU.

May 20, 2026May 20, 2026 by Mark Handley

Finland – investigation into exports of 135 trucks to Russia referred to prosecution and Customs’ updated recent enforcement statistics

Further to our earlier post, Finnish Customs has issued a press release relating to the conclusion of an investigation, that is now being forwarded to the Prosecution District of Eastern Finland for criminal prosecution.

The investigation alleges the prohibited export of 135 trucks and 29 trailers to Russia in breach of the EU’s sanctions. The vehicles are said to be valued at €17.5 million.

The Finnish exporting company declared that the exports were bound for Kazakhstan and Turkey via Russia, but the investigation showed the vehicle remained in Russia.

The same press release gives updated statistics on Finnish Customs’ recent enforcement activity with 58 cases between the start of 2025 and March 2026.

In 2025 the following offences (which are of differing levels of severity) were registered:

26 non-aggravated regulation offences;
17 aggravated regulation offences; and
3 non-aggravated sanctions offences.

Between January and March 2026 Customs registered the following:

2 non-aggravated regulation offences;
6 aggravated regulation offences;
1 non-aggravated sanctions offence; and
3 aggravated sanctions offences.

March 23, 2026March 23, 2026 by Mark Handley

Finland – three investigated for €17m in exports of trucks and trailers to Russia and 43 sanctions investigations by Customs in 2025

Finland’s Customs has issued a press release relating to a criminal investigation into the alleged export of 135 trucks and 29 trailers to Russia from Finland in 2022 and 2023.

It is alleged that the destination of the exports was Kazakhstan or Turkey with Russia only as used for transit, but that the vehicles remained in Russia. The vehicles are valued at €17m.

One individual, the owner of the company, has been detained pending further investigation on suspicion of an aggravated sanctions offence, and two employees are also suspects.

Finland’s Customs does not name the company involved, but press reporting has suggested it is Idän Liikennevälitys IL oy from Lappeenranta.

Customs also state that this case is part of a larger investigation into the export of 558 trucks and 45 trailers to Russia valued at €79m.

The same Customs press release states the during 2025 Customs identified 43 sanctions offences of which 17 were classed as “aggravated”.

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, 2025March 3, 2026 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 bring 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.