General – Page 3 – European Sanctions Enforcement

February 28, 2025February 28, 2025 by Mark Handley

United Kingdom – HMRC has opened 65 trade sanctions investigations since 2022

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.

February 28, 2025 by Mark Handley

Italy and Estonia – extradition of sanctions suspect to Estonia

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.

February 24, 2025February 24, 2025 by Mark Handley

Netherlands – updated Russian sanctions enforcement statistics

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.

February 20, 2025February 20, 2025 by Mark Handley

Sanctions enforcement in 2024: Europe vs the US

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.

February 17, 2025 by Mark Handley

Netherlands – conviction for breach of ISIS sanctions

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.

February 17, 2025February 17, 2025 by Mark Handley

Ireland – charges of Russian sanctions breaches not pursued following Gardaí investigations

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.

February 17, 2025February 17, 2025 by Mark Handley

Netherlands – arrest of individual for suspected financial sanctions breaches

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.

February 17, 2025February 17, 2025 by Mark Handley

Spain – five arrested for suspected chemical exports to Russia

The Spanish authorities have issued a press release confirming a series of raids in the provinces of Barcelona and Valencia and the arrest of five people.

The raids and arrests are said to be the second phase of Operation Probirka, the first phase of which was conducted in October 2024 (see our previous post).

The bodies involved were the National Police and the Tax Agency.

The allegations include the use of front companies and dummy intermediaries in Kyrgyzstan and Armenia, and the export of chemicals which can be used in the manufacture of explosives and chemical weapons.

February 10, 2025February 10, 2025 by Mark Handley

United Kingdom – designated person charged with failing to disclose their assets

Further to our earlier post regarding the UK’s Charity Commission investigating Aozma Sultana in relation to possible sanctions breaches, it has now been reported (first by GIR – behind a paywall), that Aozma Sultana has been charged with sanctions offences in the UK and that she appeared in court last week.

Ms Sultana is a designated person under the UK’s anti-terrorism sanctions.

The alleged offence is one of refusing or failing to comply with a request from HM Treasury for information as to her assets and finances.

Trial is currently set for June 2025.

February 10, 2025February 10, 2025 by Mark Handley

Germany – investigation into alleged sanctions breaches by Roman Abramovich

It is being reported that investigations have been commenced in Germany in relation to suspected sanctions breaches by Roman Abramovich.

Actions by the Federal Criminal Police Office and the Central Sanctions Enforcement Office have included raids on properties and the confiscation of luxury cars and artwork.

The suspected breaches of Regulation 269/2014 are the failure to properly or adequately disclose his frozen assets, including a 19th-century villa in Garmisch-Partenkirchen

It is also being reported that Mr Abramovich’s lawyer has said that he is not the ultimate owner of the villa or the confiscated luxury cars.