2025 – Page 7 – European Sanctions Enforcement

September 24, 2025September 24, 2025 by Mark Handley

Switzerland – investigation into alleged spyware exports

As reported by GIR (behind a paywall) a decision by the Swiss Supreme Court has revealed an ongoing investigation by the Swiss Office of the Attorney General into alleged exports of spyware software to various countries in breach of Swiss export control laws.

The investigation relates to Andrea Gambazzi, and the company Thalestris Switzerland.

The judgment itself relates to whether documents seized as part of a raid by the authorities can, or cannot, be used as part of the investigation.

The investigation is reported to have been commenced in June 2024.

September 22, 2025September 22, 2025 by Mark Handley

Poland – updated statistics on the 42 imposed sanctions fines

With grateful thanks to the Ministry of Finance and the Economy in Poland for the provision of the information, this blog can provide an up-to-date summary of the scale of financial penalties imposed by the Polish authorities in relation to Russian and Belarusian sanctions violations.

These figures relate to the period up to 28 August 2025.

In total the Polish authorities have imposed 42 financial penalties, broken down on the following basis:

24 penalties in relation to breaches of EU Regulation 833/2014, with total fines of PLN 6,850,949 (just over €1.6m);
6 penalties for breaches of EU Regulation 269/2014, with total fines of PLN 911,515 (just over €213,000);
10 penalties for breaches of the Polish Sanctions Act of 13 April 2022, with total fines of PLN 18,886,441 (€4.42m);
1 penalty under EU regulation 765/2006 in relation to Belarus, with a fine of PLN 7,367 (€1,727); and
1 penalty relating to both Regulations 833/2014 and 765/2006, with a fine of PLN 36,272 (€8,506).

This updates the statistics previously published on this blog from July 2024.

It shows that Poland has imposed a 18 fines since that time. Of those 12 were under Regulation 833/2014, four were under Regulation 269/2014, and the two smaller fines relating to Belarus have also been imposed since July 2024.

September 18, 2025September 18, 2025 by Mark Handley

Switzerland – raids on gold trading company re Russian sanctions breaches

On 12 September 2025 Switzerland’s SECO conducted raids on the Zug offices of Open Mineral AG.

This was part of an investigation into suspected breaches of Switzerland’s sanctions against gold trading from 2022, and specifically purchases of Russian gold done through a UAE subsidiary.

The company has stated that its trades were done in accordance with applicable laws and that it is cooperating with the authorities.

September 18, 2025September 18, 2025 by Mark Handley

Denmark – charges for alleged military exports to Russia

It is being reported that the Danish authorities have charged a company and two senior executives with suspected exports of components for military goods to Russia.

The investigation is reported to have started in 2023 and included raids in December of that year. The investigators also obtained permission to obtain phone taps on the phones of the two executives.

The exports are alleged to have been shipped via China.

September 16, 2025 by Mark Handley

Germany – prosecution seeks 5 year jail term for sanctions violation ringleader

It is being reported that as part of an ongoing trial in Hamburg, that the Prosecutor’s Office is seeking a jail term of 5 years and 10 months for the main defendant. It is noteworthy that the Defence is seeking a jail term of 3 and a half years underlining the seriousness of the offending.

The alleged offending relates to the export of approximately €800,000 in electrical components and laboratory supplies.

There are four other individual defendants with the prosecution seeking shorter jail terms of suspended sentences for those.

The trial has been ongoing since April, and the verdict is expected shortly.

September 11, 2025September 11, 2025 by Mark Handley

Germany – investigation into low-value import from Russia

It is being reported that the Schwerin Public Prosecutor’s Office has commenced an investigation into suspected imports of prohibited goods from Russia.

The case illustrates the appetite for investigating suspected sanctions breaches even of low value, as the cost of the goods imported is said to be €26.83: consisting of a bar of soap, a decorative piece of wood and a CD. The recipient is reported as saying that the goods were a gift from a long-standing Russian friend.

September 11, 2025September 18, 2025 by Mark Handley

Finland – CEO acquitted of sanctions charges

The result of a prosecution of a company’s CEO has been reported in the Finnish press.

The company received an order from a Russian customer for non-prohibited goods. The products then became sanctioned leading to a dispute as to whether the contract should be performed. The Russian customer threatened to bring a claim if there was no delivery.

The Finnish company’s CEO decided the best path was to go through some of the motions of an export, which would then be blocked, and this would be proof that delivery could not be made.

The company made an export declaration for the goods (motor switches), and it was at this point that the flaw in the plan became apparent.

Customs considered that the company was seeking to export sanctioned goods and investigated and charged the CEO with the appropriate sanctions breaches.

Luckily for the CEO the District Court of South Karelia this week has acquitted the CEO. The court relied on the fact that the company had taken no steps to move the goods from its warehouse, and the court found that there was no real intention to actually export.

I am very grateful to Aleksi Pursiainen, of Solid Plan Consulting, for drawing this case to my attention.

If ever there was a cautionary tale on the drastic consequences that can come from not having appropriate sanctions wording in your contracts, this is it.

September 8, 2025September 8, 2025 by Mark Handley

United Kingdom – OFSI issues Disclosure Notice for bank that allowed designated person to use funds

The Office of Financial Sanctions Implementation (“OFSI”) has today issued a Disclosure Notice against Vanquis Bank Limited.

Vanquis failed to react quickly enough to the designation of one of its customers under the UK’s anti-terrorism sanctions permitting a withdrawal (of £200) a day after the designation, and a purchase (of £8.99) five days after designation.

OFSI had written to Vanquis in advance of the designation to warn it that an unnamed customer of the bank was about to the designated. A day after the designation the Bank had flagged the possible match with a customer, but it took 8 days to confirm the match.

Just 5 days after the match was confirmed Vanquis reported the breach to OFSI.

In the overall circumstances, including the low value of the breaches, OFS declined to impose a fine.

It is worth noting that OFSI describes the breaches as VBL itself “made funds available to a designated person”, rather than facilitating or some other categorisation.

September 8, 2025September 8, 2025 by Mark Handley

Jersey – investigation into suspected Russian sanctions offences

Reporting by the Guardian newspaper has flagged an ongoing sanctions investigation in Jersey that this blog had previously missed.

The investigation has become public as a result of a Swiss judgment relating to a mutual legal assistance request for documents made to Switzerland by the Jersey authorities. The court dismissed a challenge to the provision of the documents.

As well as investigating allegations of corruption going back to the 1990s the Jersey authorities are said in the judgment to be investigating:

i) the continued use of the funds and assets of two Jersey companies (named only as J Ltd and K Ltd) after the the person who is alleged to indirectly control the companies was placed on Jersey’s Russian sanctions list;

ii) that companies continued to provide the designated person with financial services after his designation; and

iii) an attempt that was made to transfer the assets of J Ltd after the person’s designation.

The judgment itself does not name the designated person, but press reporting has identified the person as Roman Abramovich.

The Guardian also notes that lawyers for Mr Abramovich denied the allegations.

September 8, 2025September 8, 2025 by Mark Handley

Netherlands – fine for failure to provide regulator with sanctions compliance information reduced on appeal

The Rotterdam District Court has issued a judgment reducing a fine of €500,000 imposed by the AFM (Autoriteit Financiele Markten) on Tradition Securities and Futures S.A. to €100,000.

The AFM had issued questionnaires in 2020, 2021, and 2022 in relation to TSAF’s compliance with Dutch AML and sanctions laws. The questionnaires were not completed.

In June 2023 the AFM notified TSAF of the intention to impose a fine of €500,000 for the failings. This was imposed in October 2023, and the judgment is the result of an appeal against both any fine and the amount of the fine.

The appeal against the fine itself was dismissed.

In relation to the size of the fine the Court ruled that the AFM failed to take note of a range of factors in its own fines guidance, namely that there was no damage to third parties, no unlawfully obtained gain, no (major) social impact, no significant scale, and no market disruption. Further it was noted that this request for information was a generic annual questionnaire and not in the context of a particular investigation or alleged breaches of sanctions. The Court was of the view that TSAF should have benefitted from a 50% reduction upon the proper application of the fining guidance but then further reduced the fine from €250,000 on the basis that such a fine was “disproportionate “not in reasonable proportion to the nature and seriousness of the violation”.