General – European Sanctions Enforcement

May 18, 2026May 18, 2026 by Mark Handley

Switzerland – investigation into financial sanctions circumvention

As part of the Annual Report for 2025, Switzerland’s Federal Police Agency (Fedpol) has included information on an investigation into Russian funds held by an unidentified sanctioned Russian oligarch (the report uses the name “Aleksandr*” but this is not the person’s real name.

The report makes mention of a number of suspicious activity reports filed by Swiss private banks, and cooperation with an unnamed foreign country led to a significant investigation:

“The investigation revealed that Oleg and Dimitri owned assets in several cantons. The competent foreign criminal prosecution authority submitted a request for mutual legal assistance to the Federal Office of Justice with the aim of searching the premises and seizing the assets of Oleg and Dimitri, in particular bank accounts and real estate. A cantonal public prosecutor’s office was responsible for processing the request for mutual legal assistance. fedpol coordinated the case in Switzerland and abroad. By the end of 2025, the operation was underway, with more than 50 Swiss investigators and prosecutors from several cantons involved.

The seizures would first take place in Switzerland, with further actions in other European countries scheduled to follow. To this day, this remains one of the largest cases involving money laundering for the purpose of evading sanctions“.

The report does not discuss the outcomes of the investigation so far.

May 11, 2026May 11, 2026 by Mark Handley

Sweden – raids and two arrested as part of Russian sanctions breach investigation

The Swedish Security Service has issued a press release confirming raids on multiple residential properties in southern and western Sweden, as well as the arrest of two individuals suspected of gross violations of the EU’s sanctions against Russia.

The breaches are said to relate to the “procurement of advanced products on behalf of Russia” but no further detail has been provided at this stage.

May 8, 2026May 8, 2026 by Mark Handley

Latvia – sanctions enforcement data from Customs for the first quarter of 2026

A few weeks ago, Latvia’s Customs Service published data on its sanctions enforcement actions for the first quarter of 2026.

This includes:

161 shipments destined for prohibited export to Russia and Belarus were stopped;
26 shipments intended for prohibited import from Russia and Belarus were stopped;
43 attempts to export cash to Russia were prevented;
42 cases of violation by individuals using the postal service;
29 administrative proceedings were commenced for violations of sanctions; and
18 cases were referred to initiate criminal prosecutions.

May 8, 2026May 8, 2026 by Mark Handley

Poland – publication of sanctions enforcement statistics including 138 fines imposed

The government of Poland has issued a press release detailing its efforts to date on the enforcement of the EU’s sanctions against Russia and Belarus.

My thanks to Dr Marcin Lukowski for drawing this release to the blog’s attention.

To date Poland has:

imposed fines of PLN 74.4m (c. €18m) across 138 separate fining decisions; and
in the first quarter of 2026 there are:
- 191 pending cases;
- 122 cases where an individual has been identified as a suspect (“charged” in Polish terminology);
- 13 indictments filed; and
- 10 final judgments.

The government also states that it has frozen €546.2m in assets, and that nearly 56% of all EU customs alerts originate from Poland.

As per our earlier post from September 2025 – at that stage Poland had imposed 42 fines for a total of PLN 26.6m or €6.2m, meaning the number of fines, and the value of fines imposed, has nearly tripled since September last year.

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 20, 2026April 20, 2026 by Mark Handley

Belgium – seizure of planned exports of military goods bound for Israel

The Belgian authorities have intercepted a shipment at Liège airport of 33 crates of military goods to be exported to Israel without an appropriate export licence.

The goods were transiting through Belgium having been shipped from the UK.

The goods are stated to have included: “lasers, sights, fire control systems and parts for fighter jets”.

April 6, 2026April 6, 2026 by Mark Handley

Sweden – sanctioned (and suspected of leaking) tanker seized (and released)

On Friday 3 April, the Swedish Coast Guard boarded and seized control of the sanctioned “shadow fleet” tanker the Flora 1. The vessel is suspected of having caused a 12 km (8 mile) oil spill in the Baltic Sea near the island of Gotland.

The vessel was then anchored off Ystad.

The Coast Guard’s press release states that the vessel’s flag status is uncertain, and states that “this is the first time we have been able to trace a discharge to a vessel subject to sanctions, and which may be suspected of environmental crimes”.

We have updated our vessel seizure tracker.

The vessel has since been released, with the Coast Guard citing a lack of evidence linking the vessel to the oil spill, and that the Coast Guard had been able to confirm the flag status of the vessel.

April 6, 2026April 6, 2026 by Mark Handley

Bulgaria – extradition to face US sanctions charges

Further to our earlier post, it is now being reported that the Bulgarian authorities have extradited Russian national Oleg Olshansky to face charges of breaching the US’s Russian sanctions and money laundering.

Mr Olshansky had appealed an earlier decision approving his extradition.

Mr Olshansky and another Russian national extradited from Bulgaria, Mr Sergey Ivin have now been charged by the US authorities.

April 6, 2026April 6, 2026 by Mark Handley

Germany – 14 addresses raided in investigation into suspected Russian exports by three companies

German Customs has issued a press release announcing raids as part of investigations into the suspected Russian exports by three separate companies. A total of 14 residential and commercial properties were raided in the Rhine-Main area.

The press release states that the investigations first arose out of a routine Customs audit:

“there is a suspicion that two of the companies have commercially exported various machine parts and chemical substances to Russia in violation of an existing ban. To this end, they allegedly used a transport company and other foreign logistics service providers to sell or export sanctioned goods from the Rhine-Main region to the Russian Federation without authorisation by means of so-called circumvention exports via neighbouring states”.

The actions of the third company are not specified.

March 26, 2026March 26, 2026 by Mark Handley

Sweden – raids on “large company” and two arrests in sanctions investigation

Sweden’s Public Prosecutor has issued a press release making public raids conducted this morning at the premises of an unnamed “large company” in Sundsvall.

Two unnamed “people in senior positions” have also been arrested on suspicion of aggravated sanctions violations.

The press release does not include information on the suspected breaches.

Given the web links to information on Sweden’s Russian sanctions included in the press release, the investigation is very likely to relate to suspected breaches of the EU’s Russian sanctions.