Further to our earlier post, it is being reported that, on Sunday 2 August, the EU’s operation EUNAVFOR MED Irini has boarded another tanker, the Toa Payoh, off Sicily. The vessel was sailing from Benin to Istanbul.
The boarding was to determine and investigate the flag status of the vessel which was claiming to have recently switched to a Cameroonian flag.
The vessel was not seized or detained as part of the operation.
On 27 July, the UK’s HM Revenue and Customs issued a “Notice to Exporters” relating to two companies fined £216,530.30 and £20,889.15 respectively.
The companies were not named.
The conduct was not described in any detail and only said to “relate to unlicensed exports of military-listed goods and related activity prohibited by The Export Control Order 2008 and contrary to The Customs and Excise Management Act 1979”.
The details of why and how these companies were able to secure a resolution via a compound penalty were also not provided, although the Notice says in general terms:
“Compound settlements may be offered where an exporter has:
It is being reported that on 20 July, the EU’s Mediterranean naval taskforce IRINI boarded the Turkish-owned oil tanker, the South Star, in order to assess and investigate its flag status. Under a different name the vessel had been designated by both the EU and the UK in 2025.
The report states that there was uncertainty over the vessel’s flag status as between Cameroon and Equatorial Guinea.
The vessel was allowed to proceed after the boarding and inspection.
The same reporting refers to IRINI’s published information which says that it had conducted three earlier flag verification boardings during the month of June.
Further to our earlier post reporting on the UK’s investigation into Airbus, HMRC has today issued a Notice to Exporters that Airbus Operations Limited (AOL) has entered into a compound settlement with HMRC under which it will pay a fine of £6,409,388 for offences under The Export Control Order 2008.
This is the largest fine imposed by HMRC under the compound settlement regime, and is another example of the new practice of sometimes naming companies that enter into such settlements.
The offences do not relate to sanctions but to the UK’s strategic export controls regime.
The breaches took place “over a sustained period” before November 2022 and were self-reported by AOL which cooperated with the investigation and has implemented remediation.
The breaches are described in only general terms as follows:
The UK’s HMRC has released enforcement statistics for 2025 and the first part of 2026 in a “Technical Note”:
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.
Further to our earlier post, on 9 July, the charges against the art gallery Hauser & Wirth, and art logistics company Artay Rauchweger were dismissed on the basis of a pre-trial application. The dismissal was first reported by GIR behind a paywall.
The charges related to an allegation that the gallery sold a painting to a “person connected with Russia”. The relevant statutory definition (in regulation 19A(2)(a) of the UK’s Russian sanctions regulations), is that the person must be either “ordinarily resident in Russia” or “located in Russia”. The focus for the court was the first test.
The judge held that a properly directed jury would be unable to find that there was sufficient evidence that the buyer of the artwork was “ordinarily resident” in Russia at the time of the sale in July and August 2022.
The prosecution produced evidence of a continuing connection to Russia, but the judge is reported to have held that “the statutory test is not one of continuing connection, nationality or association, but ordinary residence”.
The European Public Prosecutor’s Office (EPPO) has issued a press release relating to an investigation in Poland into suspected Russian sanctions breaches.
The Municipal Police Headquarters in Katowice and the Silesian Customs and Tax Office – Częstochowa Branch, have responded to a request for assistance from the European Public Prosecutor’s Office (EPPO) in conducting an investigation related to customs and VAT fraud, as well as sanctions breaches, arising from the importation of birch wood into Poland between October 2023 and April 2025.
The company being investigated is alleged to have falsely declared the origin of the timber as Kazakhstan, when it is alleged to have actually originated from Russia.
Further to our earlier post, it is being reported that a hearing took place in London on Thursday of last week relating to the prosecution of Ajay Pant, the Indian national who was captain of the oil tanker the MV Smyrtos.
As part of the hearing Pant’s application to be released on bail was refused and a four week trial was listed to start on 15 December.
In addition, the court has scheduled a hearing on 12 November to hear an application by the defendant to have the charges dismissed. The reporting does not mention the basis for that application.
The Dutch DNB has issued an administrative fine to ABN Amro relating to compliance failings.
The fine was reduced from €10m to €8.5m as part of a settlement with the bank.
The sanctions element relates to a number of the customers included within the DNB’s investigated sample. As part of the assessment of these client files it was determined that there was an unaddressed risk that some of the clients were involved with dual-use goods with some indicators that the bank’s customers were using intermediaries in high-risk jurisdictions to evade or circumvent the EU’s Russian sanctions. The bank was also criticised for undue reliance on uncorroborated client declarations.
The Estonian case law website has made available a number of further judgments relating to convictions for sanctions offences:
Case 1. Judgment dated October 6, 2025
This case was the prosecution of Mati-Dmitri Terestal (see our earlier post). It was alleged that he, and another, had made economic resources and find available to a designated person who was the head of Yle1 (a Russian state-owned media outlet). It was alleged that Terestal continued to operate the media outlet after it had been closed, through a front entity and had continued to provide economic resources in the form of technical equipment, and other assets.
It was also alleged that by hiring staff for the company this was making economic resources available to Yle1, as was the creation of web domains.
The County Court had convicted Terestal in January 2025, and sentenced him to 2 years and 4 months, this was suspended for three and a half years. He was also fined €7882.92.
The District Court disagreed with the County Court on a number of issues (including whether hiring staff without more amounted to the making available of an economic resource, but upheld the conviction. The sentence was unchanged.
The decision includes a discussion of the characteristics of control for asset freeze purposes.
Case 2. Judgment dated January 21, 2026
The prosecution entered into an agreement with the defendants that was upheld by the court following guilty pleas by the defendants.
The defendants (a company and a director that company) had set out to create a fake network of transactions and sales in order to import bitumen from Russia in breach of the EU’s sanctions. The fake transactions involved front companies in a range of jurisdictions including Kazakhstan and Hong Kong. One member of staff (who was either not prosecuted or separately prosecuted) had the role of maintaining a watching brief on changes to the EU’s sanctions in order to develop changes to the methodology for masking the Russian imports.
The company, Keystone Shipping OÜ, was fined €250,000, ordered to pay costs of €61,928.18 and had bitumen valued at €179,200 confiscated.
Andrey Kolesnikov, the sole director of the company, was fined €32,110 and costs of €1,329.
Case 3. Judgment dated March 6, 2026
The case was an appeal to the District Court from a judgment of the County Court which had found two men guilty of attempting to export a BMW car to Russia in breach of the EU’s sanctions against the export of luxury goods. Vladimir Palamarchuk was fined €3000 and Igor Palamarchuk was fined €2000. In addition the car, valued at over €50,000, was confiscated as the proceeds of crime.
The appeal, which was largely based on whether the car exceeded the 50,000 threshold, was denied and the fines and confiscation upheld.
The judgment relied on the EU’s FAQs in relation to the process for determining the price of an exported good.
