Consumer Products and Services – European Sanctions Enforcement

July 20, 2026July 20, 2026 by Mark Handley

United Kingdom – charges dismissed against art gallery and transporter

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”.

June 10, 2026June 10, 2026 by Mark Handley

Poland – individual fined c. €4.7m for sanctioned luxury car exports to Russia

Poland’s National Tax Administration has issued a press release confirming the imposition of a PLN 20,000,000 (c. €4.7m) fine on an unnamed entrepreneur.

This is separate from another fine of the same amount that was imposed in April on a company for luxury car exports.

The entrepreneur exported 177 cars and one motorbike between January and June 2023 each valued at over €50,000 in breach of the EU’s prohibition against the export of luxury goods to Russia with a total value of over €19m.

My thanks to Dr Marcin Lukowski for pointing me to the announcement.

May 1, 2026May 1, 2026 by Mark Handley

Germany – publication of the latest 6-monthly sanctions enforcement update

The German authorities have published the third instalment of their 6-monthly updates on their current enforcement actions.

The report highlights:

The conviction on 2 March 2026 of two individuals relating to the export of 111 luxury cars to Russia, with €20m confiscated, and jail sentences of 6 years and 2 years (the latter suspended). See our previous post.
Raids conducted in November 2025 and the ongoing investigation into the suspected export of machine tool to Russia value at €1.7m. The report confirms that the investigation by the Stuttgart Public Prosecutor’s Office and the Stuttgart Customs Investigation Office remains ongoing. See our previous post.
An investigation into five suspects for the organized circumvention of sanctions against Russia. A company is alleged to have exported technical equipment and accessories worth c. €689,000 to a company in Russia via third countries. The investigation started in February 2025 and is being conducted by the Essen customs investigation office, is ongoing. See our previous post.
The prosecution of a 41-year old suspected of exporting 236 cars to Russia valued at approximately €18.86m. See our previous post.
The arrest of five suspects on 2 February suspected of 16,000 illegal deliveries to 24 listed Russian arms companies of good worth at least €30m. The prosecution was supported by the Federal Intelligence Service (the BND). See our previous post.
On 27 March raids conducted on 14 premises in the Rhine-Main region against two companies suspected of exporting machine parts and chemicals to Russia. A third company is said to have been involved in the alleged use of a transport and logistics companies to try and circumvent the EU’s sanctions. See our previous post.
The ongoing investigation into a member of the Saxon state parliament for allegedly falsifying the export declaration in relation to a telescopic handler rather than stating the correct destination of Belarus. Searches were conducted at residential and business premises. See our earlier post.

The update also reports on a decision of the CJEU from 5 February 2026 upholding the seizure by German customs of a Mercedes car purchased in Russia and imported to Germany. The CJEU held that the single specific import did not need to “generate significant revenue for the Russian state”, so long as the general category of goods did.

Further cases noted previously in the blog over the last few months, but not included in the report are:

an investigation from February 2026 in relation to the import of goods valued at over €4m from Russia;
an investigation made public in January 2026 into the use of RussPost to export goods to Russia;
reporting from January 2026 into a mutual legal assistance request made to Ukraine as part of an investigation into the suspected export of drone parts to Russia;
the arrest in January 2026 of two people on suspicion of making available funds and economic resources to the Donetsk and Luhansk People’s Republics;
an investigation made public in December 2025 by the Munich Prosecutor’s Office into alleged export of 50 luxury cars valued at over €10m; and
raids in November 2025 in relation to the suspected export of 346 cars to Russia.

April 21, 2026April 21, 2026 by Mark Handley

Poland – company exporting luxury cars to Russia fined c. €4.7m

Poland’s National Tax Administration has fined a company based in Małopolska and run by Belarusian citizens PLN 20,000,000 – or approximately €4,726,000. The fine is administrative, and was the maximum allowable fine.

The company had exported over 100 luxury cars to Russia via Lithuania and Belarus in breach of EU sanctions.

The total value of the cars is said to have been PLN 49m. The press release states that “The evidence gathered indicates that the company’s managers acted knowingly and deliberately participated in the circumvention of sanctions”.

The press release does not mention if proceedings are also being brought against the individuals involved or if the company will be subject to a confiscation of its profits.

March 20, 2026 by Mark Handley

Germany – individual charged with exporting luxury cars to Russia

Further to our earlier post, following raids in November 2025, the German authorities have issued a press release reporting on the charging of a 57-year old from Dessau-Rosslau, with exporting €7.6m worth of luxury cars to Russia in breach of EU sanctions.

It is alleged that he has been responsible for the export of 236 cars, and is facing 154 charges.

March 16, 2026March 16, 2026 by Mark Handley

Estonia – two companies and two people investigated for alleged exports of 209 cars to Russia

It is being reported that the Estonian authorities are investigating a large-scale scheme to export luxury cars to Russia in breach of the EU’s sanctions.

Two individuals and two companies are suspected of exporting 209 vehicles valued at €25 million.

So far one individual, an Estonian national, has been arrested and is in custody pending further investigations – the court having determined her to be a flight risk.

March 4, 2026March 4, 2026 by Mark Handley

Germany – two Customs investigations into Russian imports/exports

Two previously missed investigations from German customs into luxury car exports to Russia:

A. December 16, 2025

After commencing an investigation in December 2024, and raids conducted in May 2025, German Customs obtained an asset freeze over €16.5m.

The investigation is into a 41 year-old German-Moldovan national suspected of exporting 236 vehicles to Russia valued at €18.86m.

Further searches were conducted at properties in Ger and Teuchern in December 2025.

B. February 25, 2026

Raids and property searches were carried out in Hamburg relating to a company’s managing director suspected of more than 900 prohibited imports from Russia valued at over €4m.

The press release notes that “due to the ongoing investigations, no statement can yet be made about the type of goods”.

March 4, 2026March 4, 2026 by Mark Handley

Germany – convictions, €20m confiscation and 6 years in jail for luxury car exports to Russia

German Customs has announced the result in a criminal prosecution of two individuals charged with exporting 111 luxury cars to Russia in breach of EU sanctions.

See our earlier post relating to the raids conducted in 2024.

The vehicles were armored and classified as luxury under the EU sanctions.

One defendant pleaded guilty ahead of the trial, Inna W, and was given a 2-year suspended sentence. The main defendant, Andreas M, pleaded guilty mid way through the trial. He was given a six year jail term and has been in detention since his arrest in November 2024.

The defendants had further plans for the export of another 400 cars valued at €40m.

The evidence indicated an extensive procurement network of shell companies for purchasing the vehicles before export. Customers for the vehicles included various Russian state agencies and state-owned corporations.

The sentence included the confiscation of “approximately €20m” as the proceeds of crime said to be from the individuals and the companies involved.

January 15, 2026January 15, 2026 by Mark Handley

Estonia – Tax and Customs Board sanctions enforcement statistics

As of 14 October 2025, the Tax and Customs Board of Estonia has started to publish weekly summaries of its activity, including the enforcement of sanctions at the various customs points with Russia.

Based on these weekly summaries the identification of a sanctions breach by customs officials results in one of four outcomes: 1) the import/export is prevented without further actins being taken; 2) an investigation is commenced; 3) a criminal proceeding for a misdemeanour offence is started; or 4) an on-the-spot fine is issued.

Based on the weekly reports since mid October, the following enforcement actions in categories 1-3 can be identified:

3 investigations started;
10 criminal prosecutions for misdemeanour offences started;
14 on-the-spot fines, imposed, with values of €120, €304, €600, €1600, €1600, €800, €80, €240, €800, €600, €800, €400, €800 and €2000 (total of €10,744).

The offending is dominated by the small-scale carriage of luxury goods and euro notes.

The weekly summaries that include sanctions enforcement can be found here:

In addition, back on 18 August 2025, the Tax and and Customs Board published a half-yearly sanctions enforcement update – not previously reflected here.

This identified the following enforcement statistics:

585,000 identified border crossings
4,300 sanctions violations detected (said to be down 1,000 from the previous year)
on-the-spot fines of c. €93,000 imposed
413 misdemeanour proceedings initiated
19 more serious criminal proceedings initiated

December 3, 2025December 3, 2025 by Mark Handley

Germany – investigation into businesses alleged to have exported €10m in luxury cars to Russia

It is being reported that the Munich Prosecutor’s Office is investigating a number of businesses suspected of exporting 50 luxury cars to Russia in breach of the EU’s sanctions.

The cars are said to be valued at €10 million, including one car fitted with armour valued at €650,000.

The report alleges that the exports were done via third countries including Kazakhstan.