It is being reported that the Portuguese authorities have commenced an investigation into possible sanctions breaches by the football team Benfica.
The allegations relate to player transfers and payments between Benfica and the Russian club Lokomotiv Moscow, which is owned by the sanctioned Russian state-owned railway company RDZ.
The manager of Benfica, Rui Costa, is due to be questioned as part of the investigation.
Last month we posted regarding the conviction of five individuals for Russian trade sanctions offences by the Hamburg Regional Court.
It is being reported that the sentences have now been handed down.
Of the five individuals, one was given a custodial sentence of four and a half years, and two others were given custodial sentences of three years.
The final two defendants were given suspended sentences.
The offending concerned the shipment of electronic components valued at over EUR850,000 to Russia via third countries such as Hong Kong, China, Armenia and the UAE.
In an investigation led by the Public Prosecutor’s Office, the Dutch FIOD last week conducted raids on two homes and arrested one individual suspected of transferring bitcoins valued at €5,000 to individuals who had joined terrorist organizations in breach of the Dutch Sanctiewet.
The transfers are said to have taken place between 2019 and 2020.
The FIOD Press release acknowledges the support of Europol in providing technical assistance and facilitating cooperation from other (unnamed) countries.
The UK’s Office of Financial Sanctions Implementation has today issued a Penalty Notice against Colorcon Limited, in relation to its Moscow branch office making 79 unlicensed payments to the company’s employees and suppliers who had accounts with designated Russian banks.
The payments were made between 23 March and 2 December 2022. The company self-reported to OFSI on 21 April 2023, but OFSI’s Notice states that the four month delay in reporting meant that the reporting was not “prompt”.
After assessing a range of aggravating and mitigating factors OFSI determined that the appropriate penalty should be £235,000 to which it applied a 35% discount for reporting (down from a 50% discount available for “prompt” reporting).
The Notice also points out that further payments were made while a “wind-down” general licence was in place, but that the reporting requirements under this general licence were not complied with. No fine was issued for this breach.
In evidence before the European Parliament last week (timed at 11:29), and in a LinkedIn post today, Paulis Iljenkovs, the Deputy Head of Latvia’s FIU, has stated that Latvia currently has more than 600 criminal investigations (mostly into breaches of trade sanctions) ongoing into alleged Russian sanctions breaches.
Further to our earlier post from February 2025, regarding the Spanish authorities seizure of 13,000 tons of prohibited chemicals from being exported to Russia, it is now being reported by the OCCRP that the chemical in question was N-Methyl-2-pyrrolidone used in a range of manufacturing.
While it is reported that the Audiencia Nacional has confirmed that as yet no one has been charged, it has been confirmed that nine individuals are currently under investigation as suspects including Maria Oleinikova and her son and daughter Vyacheslav and Irina and the German national Werner Scharlau.
Maria Oleinikova declined to comment on the story due to the ongoing proceedings.
Further to our earlier post regarding Finland’s hundreds of sanctions investigations, we are pleased to acknowledge the help of Finnish Customs in supplying newly-updated information on the investigations so far commenced for breaches of the EU’s trade sanctions. These figures do not include investigations relating to financial sanctions.
While information on the penalties/sentences imposed is not available it can be noted that:
The updated figures include concluded enforcement actions up to 17 September 2025, and include some revisions to the previously supplied data for the previous years.
As previously noted the reduction in the punishment of petty regulation offences between 2023 and 2024 is most likely to be attributed to the closures of the land crossings into Russia.
| Year | Petty Regulation Offence | Regulation Offence | Aggravated Regulation Offence | Total |
| 2022 | 104 | 163 | 39 | 306 |
| 2023 | 353 | 81 | 58 | 492 |
| 2024 | 5 | 59 | 35 | 99 |
| 2025 | 2 | 15 | 9 | 26 |
| Total | 464 | 318 | 141 | 923 |
With grateful thanks to the Ministry of Finance and the Economy in Poland for the provision of the information, this blog can provide an up-to-date summary of the scale of financial penalties imposed by the Polish authorities in relation to Russian and Belarusian sanctions violations.
These figures relate to the period up to 28 August 2025.
In total the Polish authorities have imposed 42 financial penalties, broken down on the following basis:
This updates the statistics previously published on this blog from July 2024.
It shows that Poland has imposed a 18 fines since that time. Of those 12 were under Regulation 833/2014, four were under Regulation 269/2014, and the two smaller fines relating to Belarus have also been imposed since July 2024.
On 12 September 2025 Switzerland’s SECO conducted raids on the Zug offices of Open Mineral AG.
This was part of an investigation into suspected breaches of Switzerland’s sanctions against gold trading from 2022, and specifically purchases of Russian gold done through a UAE subsidiary.
The company has stated that its trades were done in accordance with applicable laws and that it is cooperating with the authorities.
It is being reported that the Danish authorities have charged a company and two senior executives with suspected exports of components for military goods to Russia.
The investigation is reported to have started in 2023 and included raids in December of that year. The investigators also obtained permission to obtain phone taps on the phones of the two executives.
The exports are alleged to have been shipped via China.
