General – Page 8 – European Sanctions Enforcement

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.

September 30, 2025September 30, 2025 by Mark Handley

Latvia – more than 600 criminal investigations into sanctions violations

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.

September 30, 2025September 30, 2025 by Mark Handley

Spain – updates on investigation into alleged exports of prohibited chemicals to Russia

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.

September 30, 2025September 30, 2025 by Mark Handley

Finland – 26 investigations into breaches of trade sanctions started in 2025

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:

Petty regulation offences are punishable only by fines;
Regulation offences are punishable by fine or imprisonment for a maximum of 2 years; and
Aggravated regulation offences are punishable by imprisonment of at least 4 months and not more than 4 years.

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

September 22, 2025September 22, 2025 by Mark Handley

Poland – updated statistics on the 42 imposed sanctions fines

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:

24 penalties in relation to breaches of EU Regulation 833/2014, with total fines of PLN 6,850,949 (just over €1.6m);
6 penalties for breaches of EU Regulation 269/2014, with total fines of PLN 911,515 (just over €213,000);
10 penalties for breaches of the Polish Sanctions Act of 13 April 2022, with total fines of PLN 18,886,441 (€4.42m);
1 penalty under EU regulation 765/2006 in relation to Belarus, with a fine of PLN 7,367 (€1,727); and
1 penalty relating to both Regulations 833/2014 and 765/2006, with a fine of PLN 36,272 (€8,506).

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.

September 18, 2025September 18, 2025 by Mark Handley

Switzerland – raids on gold trading company re Russian sanctions breaches

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.

September 18, 2025September 18, 2025 by Mark Handley

Denmark – charges for alleged military exports to Russia

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.

September 11, 2025September 18, 2025 by Mark Handley

Finland – CEO acquitted of sanctions charges

The result of a prosecution of a company’s CEO has been reported in the Finnish press.

The company received an order from a Russian customer for non-prohibited goods. The products then became sanctioned leading to a dispute as to whether the contract should be performed. The Russian customer threatened to bring a claim if there was no delivery.

The Finnish company’s CEO decided the best path was to go through some of the motions of an export, which would then be blocked, and this would be proof that delivery could not be made.

The company made an export declaration for the goods (motor switches), and it was at this point that the flaw in the plan became apparent.

Customs considered that the company was seeking to export sanctioned goods and investigated and charged the CEO with the appropriate sanctions breaches.

Luckily for the CEO the District Court of South Karelia this week has acquitted the CEO. The court relied on the fact that the company had taken no steps to move the goods from its warehouse, and the court found that there was no real intention to actually export.

I am very grateful to Aleksi Pursiainen, of Solid Plan Consulting, for drawing this case to my attention.

If ever there was a cautionary tale on the drastic consequences that can come from not having appropriate sanctions wording in your contracts, this is it.

September 8, 2025September 8, 2025 by Mark Handley

Jersey – investigation into suspected Russian sanctions offences

Reporting by the Guardian newspaper has flagged an ongoing sanctions investigation in Jersey that this blog had previously missed.

The investigation has become public as a result of a Swiss judgment relating to a mutual legal assistance request for documents made to Switzerland by the Jersey authorities. The court dismissed a challenge to the provision of the documents.

As well as investigating allegations of corruption going back to the 1990s the Jersey authorities are said in the judgment to be investigating:

i) the continued use of the funds and assets of two Jersey companies (named only as J Ltd and K Ltd) after the the person who is alleged to indirectly control the companies was placed on Jersey’s Russian sanctions list;

ii) that companies continued to provide the designated person with financial services after his designation; and

iii) an attempt that was made to transfer the assets of J Ltd after the person’s designation.

The judgment itself does not name the designated person, but press reporting has identified the person as Roman Abramovich.

The Guardian also notes that lawyers for Mr Abramovich denied the allegations.

September 3, 2025September 3, 2025 by Mark Handley

Spain – appeal court upholds pre-trial detention in Russian sanctions prosecution case

Press reporting has brought to light a Spanish judgment upholding the pre-trial detention of a Georgian national named only “Alexander” who is suspected of exporting a range of goods and machinery to Russia via Turkey.

The judgment is here.

It is alleged that the individual had company seals for a range of Spanish, Turkish and Russian companies and was able to prepare documentation that gave the appearance of legitimate exports to Turkey.

WhatsApp messages, however, are said to have revealed the end-customers in Russia.

It is unclear whether this judgment relates to another Spanish investigation related to the export of machinery through third countries (see our earlier post), or is a separate investigation.