Consumer Products and Services – European Sanctions Enforcement

November 5, 2026November 5, 2026 by Mark Handley

Belgium – investigation into suspected breaches of Myanmar sanctions

It is being reported that Belgium’s Federal Public Service (FPS) Finance is investigating whether breaches of the EU’s Myanmar sanctions have taken place.

The investigation arises out of Monde Selection, the consumer goods awards company, including products in its award selection made by a Myanmar beverage company owned by sanctioned state-owned companies.

The company says it has severed all contact and revoked awards issued as well as removing the products from its website. A spokesperson is quoted as saying that it was unaware of the sanctioned status of the producer at the time.

It is unclear whether the investigation relates to the receipt of fees from the Myanmar company, or whether the view is being taken that the publicity provided to the sanctioned entity would constitute “economic resources” comparable to an OFSI fine imposed in 2022. In that case the publicity afforded to a sanctioned entity by including its wine in a competition was said to amount to making an “economic resource” available to a designated person.

November 2, 2026November 2, 2026 by Mark Handley

Estonia – Customs enforcement statistics for sanctions since 2025

Estonia’s Customs body issued a press release back in August, detailing its enforcement actions in relation to Russian and Belarusian sanctions since the start of 2025.

1.05 million customs checks of which 47,000 were trucks and vehicles.
8143 violations detected averaging 13 per day, mostly relating to the attempted export of cash and/or consumer goods.
1017 misdemeanour proceedings commenced, of which 931 have reached a decision.
The average fine across the 931 determined cases was €269, for a total of just over €250,000.
146 criminal proceedings commenced, for the more serious conduct.

November 2, 2026November 2, 2026 by Mark Handley

Italy – investigation into Italian national suspected of providing Crimea tourism services

It is being reported that Italy’s Financial Security Committee is investigating the case of Italian national, Marco Maggi, who is resident in Russia.

The allegation is that he operates a company that provides tourism services, and in particular hunting trips, in Crimea in contravention of the EU’s sanctions.

Article 2(d) of EU Regulation 692/2014 reads: “It shall be prohibited to provide services directly related to tourism activities in Crimea or Sevastopol”.

October 29, 2026November 3, 2026 by Mark Handley

Estonia – Customs enforcement data for Russian sanctions since June 2026

Further to comparable previous posts, the weekly updates from Estonian Customs have given examples of a range of enforcement actions, including many blocked exports and imports.

The commencement of four misdemeanour proceedings were commenced, primarily for the export of significant amounts in euro banknotes.

The updates also provide the details of nine on-the-spot fines imposed totalling €3876

October 7, 2026October 7, 2026 by Mark Handley

Lithuania – fine of €418,677 for Belarus sanctions breaches upheld in court

It is being reported that the Regional Administrative Court of Lithuania has upheld a challenge to a fine of €418,677 imposed by the Financial Crime Investigation Service against the company Dage Capital for breaching the EU’s sanctions against Belarus.

The company sold luxury cars to entities in Poland and the UK for on-sale to Belarus.

The company was also found to have used accounts with the designated Alfa-Bank in Belarus.

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.