General – European Sanctions Enforcement

April 10, 2025April 10, 2025 by Mark Handley

United Kingdom – first criminal convictions under the UK’s Russian sanctions

It is being reported that the jury in the criminal prosecution of designated person Dmitrii Ovsiannikov, his wife Ekaterina Ovsiannikova, and his brother in law Alexei Owsjanikow have returned two guilty verdicts and one acquittal.

See our earlier posts on the progress of this case here and here.

These are the first criminal convictions obtained by the UK authorities under the UK’s Russian sanctions regime, and the first criminal conviction under any sanctions regime since 2017. It is also a rare example of the prosecution of a designated person.

Ekaterina Ovsiannikova was acquitted on four counts of circumventing sanctions arising from payments to her husband of £76,000 in 2023.

Alexei Owsjanikow was acquitted of several counts relating to access to a car, arranging car insurance and use of a bank account. He was, however, convicted of two counts of circumventing sanctions relating to the payment of £41,027 in private school fees.

Dmitrii Ovsiannikov was convicted of six of the seven counts he was charged with, all relating to breaches of the asset freeze imposed upon him by reason of his status as a designated person.

Sentencing will take place in due course, and it is to be hoped that the judge’s Sentencing Remarks are made public.

April 10, 2025April 10, 2025 by Mark Handley

United Kingdom – export control compound penalties issued totalling £3.7m

Yesterday the UK’s HMRC issued a Notice to Exporters publishing three recent compound penalties issued to exporters.

In line with HMRC policy when agreeing to a compound penalty resolution, the information provided on the offending, the offender, and the co-operation provided is limited, although in this instance it is specified that the penalties do not relate to sanctions breaches. The detail available states:

The settlements relate to unlicensed exports of military-listed goods and related activity prohibited by The Export Control Order 2008 and contrary to The Customs and Excise Management Act 1979. These do not relate to sanctions offences.

The 3 settlements agreed with UK companies were:

January 2025 – £10,900.00 was paid for export license breaches in relation to the export of military goods controlled by The Export Control Order 2008
February 2025 – £431,232.20 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008
February 2025 – £3,231,762.40 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008“.

April 8, 2025April 8, 2025 by Mark Handley

Switzerland – Attorney General’s Office provides details on two ongoing criminal sanctions cases

The Annual Report of the Swiss Attorney General’s Office (OAG) contains details on two ongoing criminal sanctions cases which it has taken over from SECO. Both cases arise under Switzerland’s Russian sanctions.

In one the OAG state that they have conducted search at eight residential properties in the cantons of Lucerne, Zug and Nidwalden. The investigation is said to relate to both an asset freeze imposed on a designated person and suspected breaches of the Swiss Embargo Act.

Assets which are the subject of “super-provisional freezing” as part of this investigation are said to total CHF 1.3 billion (or c. €1.39 billion).

Less information is given on the second investigation other than that it is “in connection with suspected sanctions violations by a Swiss company via subsidiaries abroad”.

April 2, 2025April 2, 2025 by Mark Handley

Netherlands – person arrested on suspicion of terrorist sanctions breaches

The Dutch FIOD, has issued a press release regarding its arrest of a 32-year old man suspected of violating the Dutch Sanctiewet 1977 through the suspected transfer of bitcoins to sanctioned terrorist organisations between 2020 and 2022.

The investigation was commenced as a result of a suspicious activity report made by a crypto exchange to the Dutch FIU.

April 2, 2025April 2, 2025 by Mark Handley

Switzerland – updated enforcement statistics with 9 new convictions since September 2024

Switzerland’s SECO has given an update on its ongoing enforcement actions.

It has received 600 reports of suspected sanctions breaches, and it has opened 68 penalty proceedings, of which 24 have resulted in final fines.

As per our earlier post, as of September 2024 the figure was at 15 final convictions, meaning that another 9 have been added since then.

No figure has been given for the penalties imposed.

April 2, 2025 by Mark Handley

Switzerland – update on ongoing criminal sanctions proceeding

Further to our earlier post from August 2024, the Swiss authorities have provided an update on one of their ongoing criminal sanctions investigations.

The investigation relates to people linked to Suleiman Kerimov, a designated person under Swiss sanctions.

As of August 2024 it was an investigation into four people, it is now being reported that the Swiss authorities have confirmed that the case has moved to an ongoing criminal proceeding, and that there are five individual defendants.

April 2, 2025 by Mark Handley

France – TV regulator orders satellite provider to stop broadcasting sanctioned Russian channels

The French media regulator , Arcom, has issued an order to Eutelsat ordering it to cease the broadcasting of two channels owned or controlled by JSC National Media Group which is a designated person under the EU’s Russian sanctions.

The channels are STS and Kanal 5.

Earlier reports had suggested that Arcom might impose a fine on Eutelsat, but no fine was imposed.

April 2, 2025 by Mark Handley

Germany – four charged under ISIS sanctions

It is being reported that the German Prosecutor’s Office has charged four Russian nationals with making funds available to ISIS in breach of the EU’s sanctions.

One individual was arrested in January of this year and three others in July of 2024.

They are accused of raising €174,000 for ISIS and then sending that to ISIS via various channels.

March 21, 2025April 3, 2025 by Mark Handley

United Kingdom – enforcement update from the OFSI annual report for 2023/24

OFSI has published its annual report for the year 2023/2024.

The report provides the following data:

2021/22 – 147 investigations opened (and 101 closed);

2022/23 – 473 investigations opened (and 74 closed); and

2023/24 – 396 investigations opened (and 242 closed).

Of the 396 investigations opened in 2023/24, 288 were as a result of self-reporting with 108 opened through pro-active investigation or other means.

Further, OFSI’s report gives a break down of which sanctions regimes the investigations relate to:

347 to Russian sanctions;
21 to Libyan sanctions;
9 to Iran sanctions; and
19 across the other regimes.

The report also gives a break down of the 242 investigations closed during the year of the report:

133 closed with a finding of no breach and sending a “No Further Action” letter;
18 closed with a finding there was a breach and sending a “Warning” letter;
1 closed with a finding of a breach and a referral to a regulator;
1 closed with an OFSI public disclosure;
61 closed without a final determination that there was a breach and sending a “No Further Action” letter; and
28 investigations closed for “Other” reasons.

March 5, 2025 by Mark Handley

Estonia – 8 sanctions convictions and more than 100 active criminal cases

The Yearbook of the Prosecutor’s Office in Estonia has published details on its enforcement of sanctions to date.

I thank Siiri Grabbi of the Coop Pank in Tallinn for the reference.

The Yearbook states that eight criminal convictions have been obtained with one also appealed. It does not provide details of the offending or the sentences imposed.

The Yearbook further notes that the Prosecutor’s office currently has more than 100 active criminal cases.