2025 – Page 8 – European Sanctions Enforcement

September 8, 2025September 8, 2025 by Mark Handley

Netherlands – company convicted of sanctioned exports ordered liquidated

Further to our earlier post from October 2024 reporting that a company had been convicted of exporting prohibited aircraft parts to Russia and fined €165,826, a judgment published on 5 September 2025 dealt with an application to liquidate the company by the Public Prosecution Service.

The company in question has now been named as Jet Air Equipment BV.

The Gelderland Court has ordered that the company be declared prohibited and that a liquidator be appointed for the dissolution of the company. The company will have the ability to make submissions on the identity of the liquidator, but the court reserved the right to make the appointment itself.

In addition an unnamed company director has been barred for 3 years from serving as a company director.

An application to have all the assets of the company be distributed to the state was denied.

The Dutch courts have previously ordered the liquidation of a convicted company.

September 8, 2025September 8, 2025 by Mark Handley

Netherlands – declination for export in breach of Iran sanctions

A civil judgement from the Amsterdam Court of Appeal has revealed the outcome of an investigation of a breach of the EU’s Iran sanctions by the Dutch authorities.

The company in question, Air Cargo Consultants BV, had acted as freight forwarder (but not the seller) for eight shipments of aircraft engines to Iran starting in 2018.

The export of these parts to Iran became newly prohibited in 2023 under EU regulation 1529/2023. The products were also barred from export to Iran under US sanctions.

On 1 October 2024 Dutch customs stopped an attempt to export a ninth aircraft engine, based on a suspicion that the products were prohibited from export to Iran under the EU’s sanctions.

On the same day that the shipment was stopped the freight forwarder self-reported all nine exports to the US authorities, namely BIS, the Office of Export Enforcement and OFAC.

The civil judgment reports that in these circumstances the Dutch authorities declined to prosecute the freight forwarder but issued a warning that any further infractions would be prosecuted.

It is unclear from this judgment what, if any action, is being taken against the seller of the engines.

September 3, 2025September 3, 2025 by Mark Handley

Spain – appeal court upholds pre-trial detention in Russian sanctions prosecution case

Press reporting has brought to light a Spanish judgment upholding the pre-trial detention of a Georgian national named only “Alexander” who is suspected of exporting a range of goods and machinery to Russia via Turkey.

The judgment is here.

It is alleged that the individual had company seals for a range of Spanish, Turkish and Russian companies and was able to prepare documentation that gave the appearance of legitimate exports to Turkey.

WhatsApp messages, however, are said to have revealed the end-customers in Russia.

It is unclear whether this judgment relates to another Spanish investigation related to the export of machinery through third countries (see our earlier post), or is a separate investigation.

September 3, 2025September 3, 2025 by Mark Handley

United Kingdom – enforcement statistics (badly described)

As part of the just-published UK’s Economic Crime Plan 2: outcomes progress report, the UK government has included the following data on the enforcement of financial sanctions:

“396 recorded cases of financial sanctions breaches in the financial year ending 2024, a 16% decrease on the previous year, but there were 242 closed cases – more than tripling the number of closed cases from the previous year“.

If the UK had identified 396 actual breaches of sanctions, this would beg the question of why there has been so little enforcement. There is, however, reason to question the data in this announcement.

In OFSI’s latest annual report (see our earlier post) OFSI stated:

“OFSI progressed a substantial number of investigations during 2023-24, recording 396 cases and closing 242, more than tripling the number of closed cases from the previous year“.

OFSI’s report is the source of the figures of 396 and 242. It would seem, therefore, that the figure of 396 relates not to identified breaches of sanctions, but to the number of financial sanctions investigations OFSI conducted during 2023-24.

September 3, 2025September 3, 2025 by Mark Handley

Luxembourg – CSSF fines Alipay €214,000 including for sanctions compliance failings

Luxembourg’s financial services regulator, the CSSF, has issued a fine of €214,000 against Alipay (Europe) Limited SA for various AML and other compliance failings.

Amongst these was a failure promptly deal with “financial sanctions related alerts”, with the CSSF noting that Alipay “would not have been in a position to apply restrictive measures in financial matters without delay”.

September 3, 2025 by Mark Handley

Estonia – extradition to US on charges of supplying US goods to Russia

The US Department of Justice has issued a press release confirming that the Estonian authorities have transferred Estonian national Andrey Shevlyakov to US custody for extradition to the US to face 18 counts of supplying US goods and technology to Russia in breach of US sanctions.

It is being reported that Mr Shevlyakov was first detained in March 2023 as part of a joint investigation between US and Estonian authorities.

August 27, 2025August 27, 2025 by Mark Handley

Latvia – investigations into sanctioned Belarusian urea imports

It is being reported that the Latvian authorities have been conducting multiple investigations into suspected imports of urea from Belarus in breach of the EU’s sanctions.

The investigations are reported to be focussed on four Latvian companies and were commenced in July.

After a referral from the Customs Administration the VID Tax and Customs Police Department initially declined to prosecute, but that decision is now the subject of an appeal brought by the Customs Administration and Latvia’s FIU.

August 27, 2025August 27, 2025 by Mark Handley

Estonia – prison sentence for offences including the attempted export of luxury goods

It is being reported that the Tartu Country Court yesterday convicted Erna Moisejeva of a range of offences including the multiple attempted exports of luxury goods to Russia n breach of the EU’s sanctions.

She was also convicted of espionage and supplying information to the FSB.

Moisejeva was sentenced to 3 years’ jail and ordered to pay court costs of €3140.

The judgment remains subject to appeal.

August 25, 2025August 25, 2025 by Mark Handley

Estonia – prosecution of lawyer for sanctions offences

Further to our earlier post, the Estonian authorities have decided to prosecute an Estonian lawyer for alleged breaches of sanctions. The Prosecutor’s Press Release states that attorney Urmas Simon has been charged with making an economic resource available to the designated person Pravfond, in the form of legal services to a third party paid for by Pravfond. Mr Simon is also charged in relation to taking payment from the sanctioned entity.

August 25, 2025August 25, 2025 by Mark Handley

UK – suspended custodial sentence for refusal by designated person to provide financial information

Further to our earlier post, sentence has been passed in relation to the conviction of Aozma Sultana for refusing the provide financial information to OFSI despite repeated requests. The judge noted that the information had still not been provided.

The judge stated that the starting point for such an offence should be a custodial sentence of 15 weeks. Evidence was presented, however, that Aozma Sultana was the primary care provider for her 38-year-old wheelchair-bound brother, who suffers from cerebral palsy.

On that basis the judge sentenced to Aozma Sultana to 10 weeks’ imprisonment, suspended for 12 months. The court also ordered Sultana to complete 50 hours of unpaid work and 25 days of rehabilitation.