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