General – Page 3 – European Sanctions Enforcement

October 28, 2025October 28, 2025 by Mark Handley

United Kingdom – OFSI annual reports provides enforcement figures

OFSO has published its Annual Report for 2024-2025.

This includes the following figures:

57 “enforcement actions” which includes fines, disclosures, warning letters and referrals to regulators;
2 fines during the period (there have been more since), although it adds that “many cases under active investigation are expected to come to decision points in 2025-2026”;
As at April 2025 OFSI had 240 “active cases under investigation”;
Of the 394 new cases in 2024-2025, 180 were not the result of a self report (i.e. these cases were the result of pro-active investigation).
- Of these 394, most were in the financial services sector (142), with the legal sector providing the next most (46);
- Very few investigations concerned either manufacturing (8) or the maritime sector (7)
- 329 of the new cases concerned the UK’s Russian sanctions;
OFSI closed 214 cases during the annual period.

October 27, 2025October 27, 2025 by Mark Handley

Denmark – corporate fine for abortive sales of sanctioned equipment to Russia

Further to our post last week, the Danish company Alfa Laval has been fined DKK 100,000 (€13,300) after a guilty please for breaches of the EU’s sanctions against Russia.

The fine relates to spare parts for a centrifuge said to be valued at just over DKK 500,000, with two sales between 3 June and 2 August 2022 being entered into with a “sister company in Russia”.

The reporting states, however, that the equipment was not actually shipped to Russia, nor payment received, with the company describing the conduct as the result of “human error”.

Since the goods in question were not supplied, transferred or exported, at this stage it is unclear exactly what the company was charged with and whether the prosecution took the view that a “sale” of the goods was completed even without delivery or payment, or whether the agreements to sell constituted an attempt or conspiracy-style offence.

This is the first example of a conviction or fine by Denmark under the EU’s Russian sanctions.

October 22, 2025October 22, 2025 by Mark Handley

Denmark – 18 charges for Russian sanctions offences

It is being reported (here – behind a paywall), that the Danish National Police have provided confirmation of the total number of criminal charges for breaches of the EU’s Russian sanctions.

The report states that, to date, 7 individuals and 11 companies have been charged with Russian sanctions offences.

From what is in front of the paywall no other information is available on these charges or their outcomes.

October 21, 2025October 21, 2025 by Mark Handley

Latvia – State Security Service seeks two prosecutions of individuals for alleged Russian sanctions breaches

Latvia’s State Security Service (VDD) has issued two press releases relating to investigations in which they have asked the Prosecution Service to initiate a criminal prosecution.

The first, relates to a Russian national with Latvian residency who is alleged to have held positions of Advisor to the General Director, Director of Finance and Chief Economist for three different Russian companies. The VDD allege that holding these offices amounts to a breach of the prohibition against providing economic and governance consultancy services to Russian companies.

The second, relates to the investigation against two individuals who managed the so-called “Moscow House” in Riga. The individuals are alleged to have “dealt” with the economic resources of Moscow House by renting out its facilities, including asking such customers to pay bills on behalf of Moscow House.

The prosecution is premised on the basis that Moscow House is owned or controlled by the Moscow City Property Department, which is owned or controlled by Moscow’s Mayor Sergey Sobyanin, who is a designated person under the EU’s sanctions, or owned or controlled by President Putin in his official capacity.

October 21, 2025October 21, 2025 by Mark Handley

Albania – investigations into possible trade in Russian and Libyan oil products

Investigative reporting by Balkan Insight has revealed a number of investigations in Albania relating to alleged imports of Russian-origin oil products at the ports of Durres and Porto Romano.

The investigations have included seizures of oil cargo from a number of vessels including in January of this year.

The same report mentions a number of investigations into alleged imports of Libyan oil in 2022 and 2023 in breach of sanctions.

Albania has broadly adopted the EU’s sanctions against both Russia and Libya.

October 10, 2025October 10, 2025 by Mark Handley

Estonia – individual sentenced to 4 years and 11 months jail for sanctions and espionage offences

It has been reported (and here) that Ivan Dmitriev, an Estonian national has been convicted of a range of offences including breaches of sanctions and espionage on behalf of Russia’s FSB.

He was sentenced to four years and 11 months in jail.

The reports do not provide detail on the conduct constituting breaches of the EU’s Russian sanctions.

October 9, 2025 by Mark Handley

Portugal – investigation into possible sanctions breaches by professional football team

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.

October 9, 2025October 9, 2025 by Mark Handley

Germany – sentencing of five individuals convicted of Russian sanctions offences

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.

October 6, 2025October 6, 2025 by Mark Handley

Netherlands – arrest on suspicion of terrorist financing

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.

September 30, 2025September 30, 2025 by Mark Handley

United Kingdom – OFSI imposes £152,750 penalty for payments made to accounts held with designated banks

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.