It is being reported that Luxembourg’s Finance Ministry has tasked the public prosecutor to investigate suspected sanctions circumvention, and possible insider trading, by ex-managers of Gazprombank Luxembourg.
The bank and one of the ex-managers has denied wrongdoing.
The allegations arise out high profile reporting (behind a paywall, but also here) of a bond-trading scheme whereby cut-price Luxembourg bonds were swapped for full-priced bonds in Russia.
Finland’s Customs has issued a press release relating to the latter stages of an investigation into suspected exports to Russia of nearly €6m in “hydraulic pumps and motors as well as various valves” in breach of the EU’s sanctions.
The exports were declared as destined for Kazakhstan and Türkiye, but are alleged to have been exported to Russia.
Two individuals are the suspects with the offences treated as aggravated offences. One of the suspects is also said to be the subject of four other criminal matters pending in the courts.
The press release note that the case will be forwarded to prosecutors by the end of the year.
The Norwegian company Telenor ASA has issued a press release confirming that it is the subject of an ongoing investigation by Norwegian authorities into suspected breaches of sanctions against Myanmar.
The press release notes a police search took place earlier today at the company’s premises and that there has been an ongoing dialogue with the authorities “for a long time”.
The press release also quotes the company’s Media Relations Director as saying:
“Our employees risked imprisonment, torture or the death penalty if the military authorities’ orders were not complied with. This was a very demanding situation in which we found that we had no real choice and that we could not put our employees’ lives at risk”.
A press release from Norway’s National Criminal Investigation Service confirms that the company has been charged both with sanctions offences and human rights related offences.
The investigation relates to the period before the sale of Telenor’s operating subsidiary in Myanmar in 2022 and relates to both the transfer of “historical traffic data on customers” and “sanctioned surveillance equipment”.
It was only in March that the blog passed the milestone of 700 posts, and now it is at 800. To mark the occasion we are publishing some graphs on the current state of enforcement across Europe.
Fines
The first graph shows (in blue columns) the annual values (in euros) of fines/confiscations/penalties/forfeitures for sanctions breaches across Europe from 2017 to 2026.
The green line is the number of fines in any given year valued at €1 million or more.
With nearly four months to go 2026 is at €115.3m and is on track to surpass both 2024 and 2019 in terms of total value (and 2019 had a single fine of £102m from the UK’s FCA).
What the graph also illustrates is that while 2018-2020 had a small number of very large fines, countries across Europe are now imposing a much higher number of significant fines than before.
Jail terms
The next graph is another way of showing the sea change in enforcement outcomes since 2022.
In the last three years over 175 years of jail time (not including suspended sentences) have been handed down. The adoption and implementation of the EU’s harmonization directive, is only going to reinforce and further drive this trend as more member states take on the power to impose a custodial sentence.
The UK’s HM Revenue and Customs has issued its largest sanctions-related Compound Penalty to date.
The company, Illumina Cambridge Limited, was fined £7,438,840.13 for breaches of the UK’s Russian sanctions.
The published Notice gives limited information on the breaches:
“Between July 2022 and January 2023 Illumina breached regulation 25(1) through their involvement in the supply of sanctioned goods from one overseas company within their corporate group to another overseas company within their corporate group for export to Russia and other destinations“.
Regulation 25(1) prohibits the direct or indirect making available of “restricted goods” or “restricted technology” either for use in Russia, or to a person connected with Russia.
Illumina Cambridge Limited voluntarily disclosed the conduct to HNRC and cooperated with the investigation.
As noted by HMRC “sanctions breaches can occur when UK businesses are involved in supply chains that result in sanctioned goods being supplied indirectly to Russia (or other countries subject to trade sanctions), even when no goods have been exported from the UK“.
This is the third large fine/forfeiture handed out by UK authorities in the last few weeks following the £4.7m fine from OFSI (2 September) and the $5.2m forfeiture from the National Crime Agency (27 August).
In an Administrative Sanction published by Luxembourg’s CSSF, a fine of €56,000 was imposed on Stonehage Fleming Luxembourg S.A.
Most of the notice relates to AML compliance failings, but included was a complaint as regards to the resolution of sanctions screening hits and a delay in implementing changes to lists for screening purposes:
“At the time of the on-site inspection, hundreds of name screening alerts had been treated with significant delays and 42 alerts remained unnoticed by the PFS. These delays constitute a breach of the obligations foreseen in Article 3(2) point (d) of the AML/CFT Law and in Article 33(1) of CSSF Regulation No 12-02, as the PFS was unable to identify “without delay” persons subject to restrictive measures in financial matters and therefore apply “without delay” potential restrictive measures in financial matters as the case may be“.
It is being reported (here, behind a paywall), the Sweden’s Supreme Court has approved an request for a Russian national to be extradited to the United States to face charges arising from the alleged export of military components to Russia via Hong Kong.
Further to our earlier post regarding a Luxembourg investigation into possible EU sanctions breaches by the company Spacety Luxembourg SA, it is now being reported that the Luxembourg authorities have discontinued the investigation.
A government spokesperson is reported to have stated that the investigation was discontinued after several mutual legal assistance requests had been made, but it is unclear whether these requests were refused, and to which countries the requests were sent.
The company was placed into liquidation in October 2025.
Further to an earlier post, it is being reported that police investigators from Czechia’s National Centre for Combating Organized Crime, who have been investigating alleged breaches of the asset freeze imposed on a designated person under the EU’s Russian sanctions, have now handed the case file to prosecutors for a final charging decision.
It is alleged that Dmytro Kalantyrskyi conducted multiple transactions in 2015 relating to frozen funds in the value of CZK 96 million (nearly €4m).
A broadcast news story has provided data on the enforcement activity of Latvia’s Customs.
The story reports that:
The new story does not state over what period the confiscations took place.
