General – European Sanctions Enforcement

September 9, 2026September 9, 2026 by Mark Handley

The blog’s 800th post – fines and jail terms

It was only in March that the blog passed the milestone of 700 posts, and now it is at 800. To mark the occasion we are publishing some graphs on the current state of enforcement across Europe.

Fines

The first graph shows (in blue columns) the annual values (in euros) of fines/confiscations/penalties/forfeitures for sanctions breaches across Europe from 2017 to 2026.

The green line is the number of fines in any given year valued at €1 million or more.

With nearly four months to go 2026 is at €115.3m and is on track to surpass both 2024 and 2019 in terms of total value (and 2019 had a single fine of £102m from the UK’s FCA).

What the graph also illustrates is that while 2018-2020 had a small number of very large fines, countries across Europe are now imposing a much higher number of significant fines than before.

Jail terms

The next graph is another way of showing the sea change in enforcement outcomes since 2022.

In the last three years over 175 years of jail time (not including suspended sentences) have been handed down. The adoption and implementation of the EU’s harmonization directive, is only going to reinforce and further drive this trend as more member states take on the power to impose a custodial sentence.

September 4, 2026 by Mark Handley

Sweden – extradition of Russian national to the US approved to face sanctions charges

It is being reported (here, behind a paywall), the Sweden’s Supreme Court has approved an request for a Russian national to be extradited to the United States to face charges arising from the alleged export of military components to Russia via Hong Kong.

September 3, 2026September 3, 2026 by Mark Handley

Czechia – police refer sanctions evasion case to prosecutors

Further to an earlier post, it is being reported that police investigators from Czechia’s National Centre for Combating Organized Crime, who have been investigating alleged breaches of the asset freeze imposed on a designated person under the EU’s Russian sanctions, have now handed the case file to prosecutors for a final charging decision.

It is alleged that Dmytro Kalantyrskyi conducted multiple transactions in 2015 relating to frozen funds in the value of CZK 96 million (nearly €4m).

September 3, 2026September 3, 2026 by Mark Handley

Latvia – Customs confiscates €15m in sanctioned goods

A broadcast news story has provided data on the enforcement activity of Latvia’s Customs.

The story reports that:

roughly twice a week a shipment of sanctioned goods to Russia is stopped;
30 cargoes of military goods have been stopped; and
Customs have confiscated €15m in sanctioned goods through its work at inspections at checkpoints, of which roughly €3m has so far been sold.

The new story does not state over what period the confiscations took place.

September 1, 2026September 1, 2026 by Mark Handley

Georgia – investigation into suspected sanctioned exports to Russia

The Georgian authorities have announced an investigation arising from a Azerbaijani-registered lorry attempting to cross from Turkey into Georgia in July.

The investigation arose from checks carried out at the Sarpi checkpoint. During an inspection of a lorry, the driver declared that the goods were of EU origin and were destined for Russia. The lorry was turned back.

Later the same day the lorry returned to the same checkpoint and this time the goods were accompanied by documents asserting a Turkish origin. Inspection revealed the goods to have had German and Croatian origin.

The case has been referred to the Investigation Service of Georgia’s Ministry of Finance for further action with offences of breaching sanctions and forgery the subject matter of the investigation.

September 1, 2026September 1, 2026 by Mark Handley

Netherlands – confiscation of proceeds from sanctions breaches reduced on appeal

Further to our earlier post regarding a 2024 conviction and confiscation, the Hague Court of Appeal has ruled on an appeal by the convicted defendants on the quantum of the confiscation.

The revenue from the criminal transactions was €1,924,579.20, with the first instance court allowing deductions of costs, to arrive at an initial confiscation order in the sum of €298,310. This was in line with the Dutch methodology of confiscating net profit rather than gross profit.

The defendant raised a number of arguments:

1) that there should be no confiscation;

2) that certain costs (transport, packaging, testing, etc) had been improperly not deducted from revenue;

3) that the value of confiscated goods should be credited in favour of the defendant; and

4) that the defendant did not have the financial means to satisfy the confiscation order.

All of these arguments were rejected by the Hague Court of Appeal. Despite this, the Court reduced the sum to be confiscated to €250,195. The Court provided no reasoning, or basis for, this reduction.

August 27, 2026August 27, 2026 by Mark Handley

UK – National Crime Agency agrees forfeiture of $5.2m to resolve sanctions and AML investigation

The UK’s National Crime Agency has issued a press release stating that it has entered into a settlement agreement with ENEX Premium Trading Limited, owned by Nadir Valiyev and registered in St Kitts and Nevis.

The press release states that the settlement involves no admission of criminality by either ENEX of Mr Valiyev.

The allegation that was investigated from 2024 onwards was that ENEX was involved in the shipment of stolen Ukrainian grain. The NCA obtained an Account Freezing Order in November 2024 over sums received from China between July and September 2024. It is those funds which have now been forfeited.

August 27, 2026August 27, 2026 by Mark Handley

Germany – lengthy jail terms for machinery exports to Russia

Further to our earlier post, relating to two brothers pleading guilty to sanctions offences mid-trial, the court in Germany has now sentenced (and here in German) the pair.

The younger brother was sentenced to 4 years and one month, and the elder brother to 3 years and 10 months. This was part of a plea deal in which, according to reports, admissions were also made in relation to offences that did not form part of the prosecution.

The convictions relate to 65 exports to Russia via, Turkey and Kyrgyzstan, of a total of €833,000 worth of engineering equipment and machinery used in weapons manufacturing.

August 24, 2026August 24, 2026 by Mark Handley

Austria – two convicted for exporting sanctioned machinery to Russia

Further to our previous post, it is now being reported that the Austrian investigation into suspected exports of CNC machines has ended in two criminal convictions.

A 28 year old was the director and shareholder in the Vienna-based company involved. He received a 21 month sentence of which 19 months were suspended. He was released upon his conviction having already served more than two months in detention.

The second defendant was a 24-year old who dealt with the company’s accounts and was also a shareholder. She was given a 15-month suspended sentence.

Both had pleaded guilty to the charges.

The reporting makes no mention of a financial fine, or of any confiscation of the proceeds of crime.

August 11, 2026August 11, 2026 by Mark Handley

Austria – suspected exports of military manufacturing equipment lead to raids and arrest

Austria’s Interior Ministry has issued a press release detailing on ongoing investigation and prosecution into a procurement network for the Russian arms industry.

The goods were CNC machines and related tools for metal processing. The suspected exports involved a network of companies in Turkey, the United Arab Emirates, Hong Kong, Belarus, Kyrgyzstan, South Korea, Poland and Lithuania.

End-user certificates were also forged to mask that the real customer was Russia’s state-owned arms manufacturer ROSTEC. The goods are said to have been used in the production of engines for missiles and fighter jets.

Four properties were raided in August 2025 revealing evidence of exports valued at €3.3 million mostly shipped via Hong Kong and Turkey.

Evidence of continuing intentions to export led to the arrest on 13 May 2026 of a Belarussian national who was the managing director and co-shareholder of the unnamed company. He remains in custody.