General – European Sanctions Enforcement

January 28, 2025January 28, 2025 by Mark Handley

Estonia – 83 criminal prosecutions for Russian trade sanctions violations since 2024

It has been reported that during 2024 Estonia’s Internal Security Service commenced 71 criminal cases in relation to suspected trade with Russia in breach of the EU’s sanctions, and has commenced another 12 already during 2025. These cases are said to be for the more serious, intentional or repeat offenders.

The same report note that Estonia’s Police and Border Guard Board are currently identifying an average of 12 sanctions violations per day predominantly by individuals attempted to take cash or luxury goods into Russia. This is reported to be down from a previous average of 22 violations per day.

With all people crossing the border being subject to inspection, first time offenders are required to either turn back and not cross, or to accept confiscation of the goods/items and continue the journey.

January 28, 2025January 28, 2025 by Mark Handley

United Kingdom – OFSI reveals 706 Russian sanctions investigations opened since February 2022

As first brought to wider attention by the Global Sanctions site, the UK’s Economic Secretary has provided a written answer on the UK Parliament’s website to the question: “how many investigations by the Office of Financial Sanctions Implementation into breaches of Russian sanctions (a) are open and (b) have been undertaken since February 2022“.

The answer stated that 388 cases have been investigated by OFSI and closed since February 2022, and that 318 investigations are currently open.

This is a total of 706 investigations opened by OFSI into potential or alleged Russian sanctions breaches in the UK since February 2022.

In that time OFSI has imposed two fines (here and here) in relation to Russian sanctions and disclosed one other breach by Wise Payments Limited (here).

This means that 385 of OFSI’s opened Russian investigations since February 2022 were closed without further action.

As of April 2023, OFSI was reporting it had 172 lives cases ongoing, indicating that there has been a significant increase since then.

January 22, 2025January 22, 2025 by Mark Handley

Finland – updated statistics on its 909 Russian trade sanctions investigations

As an update to our previous post on the 900 or so sanctions investigations started by Finnish Customs since the start of 2022, we can provide a more detailed breakdown of those figures.

The blog is happy to acknowledge the information and assistance provided by Finnish Customs.

To explain the figures below, under Finnish law sanctions offences are divided into three categories:

Petty regulation offences – punishable only by fines;
Regulation offences – punishable by fine or imprisonment for a maximum of 2 years; and
Aggravated regulation offences – punishable by imprisonment of at least 4 months and not more than 4 years.

Against that background, Finnish Customs has provided a break down over time of when it commenced its many investigations and the category of offending that was being investigated.

Year	Petty Regulation Offence	Regulation Offence	Aggravated Regulation Offence	Total
2022	104	158	44	306
2023	354	86	64	504
2024	5	59	35	99
Total	463	303	143	909

The drop off in investigations relating to petty regulation offences in 2024 is to be attributed to the closure of all crossings along the land border with Russia, as most of the examples in that category had been attempts to export prohibited goods by individuals in cars and other vehicles.

January 17, 2025 by Mark Handley

United Kingdom – HMRC unaware of how many sanctions investigations it is currently conducting

Sky News in the UK has made a Freedom of Information Request to the UK’s primary trade sanctions enforcement body, His Majesty’s Revenue and Customs (HMRC), asking for the “number of cases you are currently investigating”.

See the Sky News piece here (including some comments from Mark Handley of this blog).

HMRC has responded (available here and with thanks to Sky News for providing a copy).

It has said that “the number of current investigations … is not centrally recorded. To determine how many investigations are within scope of your request would require a manual search of a significant number of records, held by different business areas“.

Sky News also asked about the identities of the entities or individuals which have received the six compound penalties for breaches of the UK’s Russian sanctions.

In line with HMRC policy this information was not disclosed because “HMRC do not consider that disclosing the company name would drive compliance, promote voluntary disclosure or be proportionate“.

While this has long been HMRC’s policy, the stance of OFSI and the new Office of Trade Sanctions Implementation is that they will each name the companies subjected to fines.

FOI2024_235778_ (002)Download

January 17, 2025January 17, 2025 by Mark Handley

United Kingdom – National Crime Agency gives update on sanctions enforcement

As first reported by the BBC, the National Crime Agency has written to the Chair of the Treasury Committee of the House of Commons to respond to a series of questions about the NCAs sanctions enforcement efforts to date.

The letter confirms that there have been no convictions obtained under Russian sanctions, or indeed any sanctions regime since the coming into force of the Sanctions and Anti-Money Laundering Act in January 2021.

The NCA also stated that “a very small proportion” of its workload is sanctions-related, but it would not disclose how many cases had been referred to it by OFSI or any other body, or how many active investigations followed from the 5,600 sanctions-related suspicious activity reports it received in the year 2022-2023.

The letter also stated:

“the NCA’s Combatting Kleptocracy Cell (CKC) has delivered over 150 disruptions, which include: asset freezes and forfeiture, taking action against key enablers, and supporting international partners” and then gave a number of specific examples including the successful forfeiture of £780,000 obtained in July 2024.

Another example given was “The arrest of enablers in the regulated sector who support the transactions of corrupt elites“, although no further detail was provided.

January 6, 2025 by Mark Handley

Finland – sanctions enforcement statistics: over 900 investigations, hundreds of fines and dozens of convictions

Press reporting in Finland has provided an update on Finland’s sanctions enforcement.

The update provides:

over 900 preliminary investigations commenced by Finnish Customs:
- 13 started between 2018 and 2021;
- 306 started in 2022;
- 492 started in 2023; and
- 83 started in 2024 (January to September, with an uncertain number since then)
“More than half” involved minor regulatory offences and have been resolved by monetary fines without recourse to the court system. These cases are further described as: “The fine cases mainly concern private individuals who have exported small quantities of banned goods across the border. Private individuals have exported, for example, luxury goods, not equipment needed by the military“.
“Dozens” of convictions and fines imposed by the courts for more serious offences. These are described as: “characterized by planning, systematicity and the pursuit of significant financial gain. Most often, they involve equipment needed on the front line. … The perpetrators in such cases are typically small or medium-sized export or logistics companies“.

The report provides no further details on the precise number of fines, the amount of fines, or other sentencing involved.

A separate report notes that the Finnish Navy has established a controlled area in the Gulf of Finland where Russian-linked vessels are inspected. This de facto maritime detention zone is encircled by Finnish naval forces and that currently 20 Russian “shadow fleet” vessels are “under scrutiny, with several facing potential long-term detention“.

January 2, 2025January 2, 2025 by Mark Handley

Finland – sanctions investigation closed into returned Russian art

In April 2022 Finnish Customs seized over 200 pieces of art being shipped back to Russian museums such as the State Hermitage Museum and the Tretyakov Gallery.

It is now being reported that at that time an investigation was commenced by Finnish Customs working with the Finnish Foreign Ministry as to whether permitting the onward transit of the objects and artefacts, or the shipments themselves, would amount to breaching EU sanctions.

The artefacts were later allowed to travel on to Russia while the investigation continued.

As of 24 December 2024, it is now being reported (in the linked article above) that the investigation has concluded with no further action to be taken.

January 2, 2025January 2, 2025 by Mark Handley

Latvia – more than 100 criminal cases for sanctions breaches commenced during 2024

It has been reported that the Latvian authorities commenced 100 criminal cases for suspected sanctions violations during 2024.

In late October 2024 the figure was reported as 94, meaning that the final weeks of the year continued to see new criminal cases started.

The cases appear to be predominantly related to breaches of trade sanctions and the reporting states that the prohibited products included “engines, steel products and optical devices”.

December 20, 2024December 20, 2024 by Mark Handley

Estonia – person detained for alleged breach of designated person’s asset freeze

It is being reported that the Estonian authorities have arrested and detained a 65-year old named only as Tatjana, for allegedly managing and handling funds on behalf of the Foundation for the Support and Protection of the Rights of Russian Compatriots Living Abroad, which is a designated person under the EU’s sanctions.

It is alleged that Tatjana received €50,000 from the Foundation and used the money to fund a person’s defence in an ongoing criminal trial in Estonia.

December 20, 2024December 20, 2024 by Mark Handley

United Kingdom – three penalties imposed by HMRC for breaches of Russian trade sanctions

On 4 November 2024, HMRC published a Notice to Exporters regarding a compound penalty of £58,426.45 imposed for breaches of Russian trade sanctions.

The Notice included the line:

“Since February 2022, HMRC has issued six compound settlements against UK companies that have breached the Russia sanctions regulations for a total of £1,363,129, including one in August 2023 for £1 million“.

This struck a chord because, as captured in this blog, only three compound penalties had been publicly imposed by HMRC for breaching Russian sanctions. So a Freedom of Information request was made about the other three.

The response is here.

FOI2024_232370 Download

The response discloses details of three compound penalties (totalling c. £237,000) from August and September 2022 and April 2023. These had each been previously published, but had not previously been described as relating to Russian sanctions.

August 2022 – £1,000.00 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
- This penalty was previously described as relating to “unlicensed exports of dual-use goods”.
September 2022 – £19,689.20 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
- This penalty was previously described as relating to “unlicensed exports of dual-use goods”.
April 2023 – £217,012.50 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
- This penalty was previously described as relating to “unlicensed exports of dual use goods”.

It is unclear why these penalties were not previously described as relating to breaches of Russian sanctions.

The FOIA request also asked for the names of the individuals or companies which were the subject of the penalties; whether any had self-reported; and what (if any) confiscation of the proceeds of crime was applied. These questions were not answered.