General – European Sanctions Enforcement

August 4, 2025August 4, 2025 by Mark Handley

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.

August 4, 2025August 4, 2025 by Mark Handley

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.

August 4, 2025August 4, 2025 by Mark Handley

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:

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

July 23, 2025July 23, 2025 by Mark Handley

Denmark – raids, arrests and individuals and company charged in Russian sanctions prosecution

After press reporting had published allegations that the Danish paint company Flügger may have been continuing to trade with Russian customers via third countries in breach of EU sanctions, on 26 June the National Unit for Special Crime (NSK) conducted raids on the business premises of Flügger, and the homes of the company’s CEO and CFO.

The CEO and CFO were arrested as part of the raids, and have both been charged with sanctions offences as has the company itself.

The company has issued a press release confirming the investigation and stating that it has been deceived by distributors in Kazakhstan, Estonia, Azerbaijan and Kyrgyzstan.

July 22, 2025July 22, 2025 by Mark Handley

Estonia – lengthy custodial sentence for sanctions offences

Estonia’s Office of the Prosecutor has issued a press release regarding an agreed settlement with Pavel Kapustin convicting him of sanctions offences as well as espionage and supplying false information.

The man was sentenced to 6.5 years’ jail and assets valued at €90,000 were confiscated. The press release does not break down the sentence by offence.

The man took orders for luxury goods from Russian customers and arranged for their transport to Russia in breach of the EU’s sanctions.

This is the sixth custodial sentence handed down in Estonia for sanctions offences so far this year.

July 15, 2025July 15, 2025 by Mark Handley

Spain – investigation into alleged imports of sanctioned Russian birch

It is being reported that the Ministry of Ecological Transition in Spain is investigating a Basque company for allegedly importing 54 shipments of Russian birch plywood via China.

No other information appears to be available on this investigation.

July 15, 2025July 15, 2025 by Mark Handley

Greece – investigation into alleged imports of sanctioned Russian birch

The NGO Earthsight has published an article on its website stating that in January this year it tipped off the Greek authorities to a shipment of allegedly sanctioned Russian birch plywood coming from the company Tianma Lvjian known to “launder” Russian birch plywood.

Earthsight adds that it has now “learned that Customs authorities in Greece have detained it and several other shipments from the same supplier. Investigations are ongoing.”

While Russian birch plywood has been the subject of numerous enforcement actions, this is are rare example of a sanctions investigation in Greece reaching the public domain.

July 10, 2025July 10, 2025 by Mark Handley

Finland – investigation commenced into Helsinki logistics company for sanctioned exports to Russia

Finland’s Customs has issued a press release announcing the an investigation into a company in the Helsinki region that is suspected or arranging exports of goods to Russia via third countries including Lithuania, Bulgaria, Poland, Belarus, Kazakhstan and Kyrgyzstan.

The exports are suspected of ranging from 2022 to 2025, and to have included direct sales by the company.

The goods involved are ball bearings and industrial motors with an estimated value of €300,000.

The investigation appears to have been started with the interception of a consignment of prohibited dual-use goods which was being directly exported from Finland to Russia.

July 8, 2025July 8, 2025 by Mark Handley

Malta – fines and prosecutions for sanctions violations

As previously posted Malta’s Sanctions Monitoring Board maintains a page or listing companies that have been subjected to a fine of greater than €800 for sanctions breaches.

The page has now been updated to include the fact of a fine against:

Felicitas Trust Limited based on a “supervisory examination conducted between April and May 2023”; and
Winzon Group Ltd based on a “supervisory examination conducted between February and March 2024”.

No other information is provided, including which sanctions regime was involved.

Separately, the SMB has issued an update on Malta’s implementation of the EU’s Russian sanctions. This notes the completion of 211 inspections, and notes that some of its investigations “are cases advancing through judicial channels”.

No further information is provided on these, presumed, prosecutions.

July 8, 2025 by Mark Handley

United Kingdom – £1.1m penalty for exports to Russia

HM Revenue and Customs has issued a Notice to Exporters reporting on the imposition of a civil compound penalty against an unnamed company for making “goods available to Russia in breach of” the UK’s Russian sanctions.

The penalty is stated to be £1,160,725.67.

No other information has been published on the identity of the offender, the nature of the offending or the goods that were exported, whether there was a self-report, or the nature of the cooperation that secured a civil penalty.