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.
The UK’s HM Revenue and Customs has published a compound penalty of £374,326.07 against an unnamed UK company for “unlicensed exports of dual-use goods and failure to declare a licence to customs”.
No further details were provided as to the nature of the conduct or the basis for offering a compound penalty rather than a prosecution.
It is being reported that the Polish authorities have responded to a press request by confirming that they have 275 sanctions investigations that are ongoing.
No further information was provided on these investigations. It is unclear how many of these relate to Russian sanctions.
In a letter written from the UK’s HMRC (the body with primary responsibility for the criminal enforcement of trade sanctions) to Parliament’s Treasury Select Committee, HMRC has provided significant information on its recent enforcement efforts.
| Year | Number of investigations opened |
| 2021 | 0 |
| 2022 | 14 (all relating to Russian sanctions) |
| 2023 | 22 (20 relating to Russian sanctions) |
| 2024 | 29 (27 relating to Russian sanctions) |
Of those 65 investigations, HMRC has confirmed that 30 remain live of which 27 relate to Russian sanctions.
The letter tabulates the six fines imposed to date for breaches of the Russian sanctions, and in relation to the largest single fine of £1,000,000 imposed in August 2023 (see our earlier post), the letter notes that this fine relates to “brokering and technical assistance” and not to an actual export.
HMRC’s letter also states that a previously published compound penalty of £1,000 from September 2023 (see our earlier post) was actually for a breach of the UK’s Iran sanctions despite being described at the time as “relating to the attempted export of Dual Use goods”.
HMRC’s letter also states that in October 2024 it referred a case for possible prosecution to the Crown Prosecution Service.
It is being reported that the Estonian Prosecutor’s office has successfully completed the extradition of suspect Ivan Anchevsky, after he was arrested in Italy.
The prosecution of Anchevsky for suspected exports to Russian in breach of EU sanctions, forms part of a wider investigation including two unnamed Estonian companies and their boards of directors.
Anchesvsky, who is a citizen of both Estonia and Russia, is suspected of using his companies Melytec and Melytec Testing to export sanctions goods to Russia.
Updated enforcement statistics are being reported (here behind a paywall, and here in summary) for the Dutch Fiscal Intelligence and Investigation Service (FIOD) and from Dutch Customs.
FIOD is reported to have conducted 30 cases in the three years since February 2022, with six resulting in convictions, and twenty investigations ongoing.
Customs are reported to have started 80 cases, with 16 ongoing, and 64 settled with fines of between €500 and €200,000.
In 2024, probably for the first time ever, Europe (meaning the EU, UK, Switzerland and Norway), imposed and obtained a greater number of fines and convictions; a higher total value of fines; and also a higher single largest fine, for sanctions breaches than those imposed by the authorities in the United States.
The US figures combine the enforcement actions taken by OFAC and BIS, as well as criminal convictions secured by the DOJ.
The European figures are taken from this blog.
The US obtained 52 successfully-concluded enforcement actions, while Europe secured 118.
The US (OFAC and BIS combined) imposed fines equivalent to €56.8m, while Europe imposed a total of €88.5m.
The single largest US fine was $20m in relation to Iran sanctions. The largest fine in Europe was the UK’s £29m imposed on Starling Bank.
On 31 January the Rotterdam District Court published its decision convicting an individual of breaches of the EU’s ISIS sanctions.
The individual was sentenced to 90 days in jail, of which 74 days is suspended for 2 years. Community Service of 80 hours was also imposed.
The transfers giving rise to the offences were US$4,350 and 150,000 Syrian pounds.
The individual was also charged with financing of terrorism and human trafficking.
Ireland’s Gardaí (National Police) have confirmed to Global Investigations Review that it has referred two investigations for prosecution for alleged breaches of the EU’s sanctions imposed on Russian in the wake of the full-scale invasion of Ukraine in 2022.
It was also confirmed that the Public Prosecution Service declined to being charges in both investigations.
One such referral to the DPP was reported to have taken place in April 2023.
In March 2024 it was reported that the Gardaí had four investigations ongoing into suspected Russian sanctions breaches, but the status of those further investigations is unknown.
The Dutch FIOD has issued a press release relating to the arrest of an individual suspected of various offences including unlicensed ‘hawala’ banking and breaches of the Dutch Sanctions Law.
As part of the investigation a residential property was raised and mobile phones and other devices seized.
It is alleged that the suspect was at the centre of a network capable of large-scale financial transfers from the Netherlands to other countries.
