Switzerland – 13 administrative penalties for sanctions offences (March 2024 to July 2025)

Further to our earlier posts publishing the Administrative Penalties imposed by Switzerland’s SECO, we are providing details of a further 13 penalties imposed.

The blog is grateful to SECO for providing anonymised copies of the penalty notices.

16. Final administrative decision, dated 18 March 2024 (I.36)

Notice.

SECO was notified by Customs at Geneva Airport following the seizure of weapon parts imported from Russia.

SECO pend an investigation and determined that the parts were not for weapons intended for hunting or sport.

The importer was individual who had ordered the goods from a Russian manufacturer. This is the first instance of a fine imposed on individual by SECO for Russian sanctions breaches.

SECO assessed the breach as negligent rather than intentional, and imposed a fine of CHF 300, plus costs of CHF 360. The imported items were confiscated.

17. Administrative penalty dated 18 March 2024 (I.72)

Notice.

This notice relates to the attempted export of 4 leather bags each valued at €370, with a total value of €1,480.

The goods were returned to seller.

The notice states that this was a repeat infraction by the company in question, with it having been the subject of proceedings that were dismissed on 19 December 2022.

The export was said to be result of human error during a busy time and SECO took the view that the breach was negligent and not intentional.

The company was fined CHF 1000 with costs of CHF 560.

18. Administrative penalty dated 23 May 2024 (I.75)

Notice.

SECO’s proceedings were commenced on 8 January 2024 and relates to an attempted export by a Russian national to Russia of luxury jewelry valued at CHF 14,100 and seized at Zurich airport.

The jewelry had been sold to that person with a VAT exemption on the basis that the person was a tourist. The invoice issued by the selling company referred to the individual as resident in the Russian Federation.

SECO accepted that the breach by the seller was negligent and not intentional, and imposed a fine of CHF 4,500, and costs of CHF 1260.

The Notice contains no indication of confiscation of the proceeds from the sale, but will be of interest for sellers of luxury goods to Russian nationals, especially where there is a reason to think that the goods would be taken to Russia.

19. Administrative penalty dated 23 May 2024 (I.91)

Notice.

The investigation was started on 27 February 2024, following the shipment of 12 electric heating resistors valued at CHF 6,400 bound for Russia and stopped at Zurich airport.

SECO determined that the breach was not intentional, but a result of a negligent failure to understand which products codes were prohibited. The company was noted as having cooperated.

A fine of CHF 1,000 was imposed plus CHF 1,260 in costs.

20. Administrative penalty dated 5 June 2024 (I.80)

Notice.

This is a short notice with substantial redactions. It relates to the attempted export of flowmeters and electric motors to Russia of uncertain value.

The company was fined CHF 700 plus costs of CHF 40.

21. Administrative penalty dated 17 June 2024 (I.84)

Notice.

This Notice relates to the attempted export of prohibited goods to Russia, being spare parts for machine tools.

The goods were not confiscated but were released back to the exporter.

The company was fined CHF 500, plus costs of CHF 650.

22. Administrative penalty dated 9 September 2024 (I.90)

Notice.

This Notice relates to prohibited imports of plastic packaging from Russia valued at c. €3,536. The goods had been donated to assist with medical research and had not been purchased.

SECO took the view the breach was negligent and not intentional and imposed a fine of CHF 500 plus costs of CHF 580.

23. Administrative penalty dated 9 October 2024 (I.94)

Notice.

This relates to an attempted export referred by Swiss Customs to SECO. Seven different categories of goods were involved, six of which were prohibited from export. The goods were valued at more than CHF 15,000.

The lawful export was allowed to proceed and the others goods were all returned to the exporter rather than being confiscated.

The company had conducted google searches to determine whether the goods were subject to prohibitions, but these provided faulty answers. SECO determined the breach was negligent and not intentional and so fined the company CHF 5,000, plus costs of CHF 1,460.

24. Administrative penalty dated 18 December 2024 (I.101)

Notice.

This Notice relates to an attempted export of satellite parts to Ukraine without a licence. SECO approved a retrospective licence application to allow the export to proceed but imposed a fine of CHF 1000 plus CHF 20 in costs.

Previously SECO had taken the view that it was not permissible to apply for retrospective licences.

25. Administrative penalty dated 5 November 2024 (I.93)

Notice.

The Notice relates to the importation of prohibited goods valued at €22,650 reported to SECO by Swiss Customs. SECO commenced its investigation in July 2024. The goods in question were an electrical cabinet with customs code 8537.1000.

The importer had obtained erroneous advice that the goods had a non-prohibited customs code.

SECO prosecuted for negligent breach and imposed a fined CHF 5,000 plus CHF 850 in costs.

26. Administrative penalty dated 9 May 2025 (I.109)

Notice.

This Notice relates to an import shipment from Russia seized at Basel Airport and referred to SECO consisting of clothing valued at CHF 28,689. These were imports prohibited under Switzerland’s Russian sanctions.

SECO accepted evidence from senior company representatives that they were unaware of the existence of the prohibitions, and so SECO proceeded on the basis of a negligence, rather than an intentional, breach.

A fine of CHF 2000 plus CHF 300 in costs was imposed.

27. Administrative penalty dated 11 June 2025 (I.110)

Notice.

This Notice relates to the attempted export to Russia of goods of uncertain value with classification codes 8544.4200 (insulated cables), 3917.4000 (plastic fittings) and 8481.8000 (valves and other fittings). The exporter is said to have applied for, and been granted, a licence after the event.

The company was fined CHF 800 plus CHF 20 in costs.

28. Administrative penalty dated 9 July 2025 (I. 114)

Notice.

This Notice relates to the seizure of goods valued at CHF 11,739 bound for export to Russia, with no licence having been sought, and with product code 9027.5000 (instruments for physical or chemical analysis).

The company was fined CHF 1000 with CHF 20 in costs. The fine is described as having been for the failure to obtain a licence, and not for the attempted unlicensed export itself.

The Notice does not indicate whether the goods were returned to the exporter or confiscated.

Lithuania – Customs raids and arrests for sanctioned exports in conjunction with raids in Portugal and Bulgaria

On Saturday Lithuania’s Customs issued a press release announcing raids on a company based in Kaunas, and associated residential premises, with 11 people (employees, company managers, as well as drivers) detained and a dozen tons of equipment (valued at around €2 million) seized.

It is alleged the company was exporting to Russia via Bulgaria and Turkey based on a fictitious customer in Portugal. Contemporaneous raids were conducted in Bulgaria to seize a shipment that had already left Lithuania, and in Portugal at the premises of the Portuguese customer.

The operation was coordinated by Eurojust and Europol and with assistance from the Portuguese authorities.

The exports are described as “water treatment equipment (dosing stations, large industrial water filters (osmosis), etc.) and their components (various pumps, filters, membranes)”. The press release adds that the products were specifically designed for the Russian customer.

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.

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.

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.

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 available on the specifics of the alleged violations, or of the conviction of the Estonian national.

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.

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”.

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.

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:

  1. 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.
  2. The self-reporting by MML was considered insufficient to trigger a discount to the imposed penalty.
  3. 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).

© 2009- Duane Morris LLP. Duane Morris is a registered service mark of Duane Morris LLP.

The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

Proudly powered by WordPress