General – Page 9 – European Sanctions Enforcement

November 3, 2025 by Mark Handley

Germany – investigation into alleged luxury car exports

German Customs has issued a 16 July Press release relating to raids and an investigation into alleged exports of luxury cars worth €3.4m to Russia.

The investigation was prompted by a suspicious activity report made to Germany’s FIU.

The investigation involves Hamburg Customs Investigation Office and the Hanover Public Prosecutor’s Office.

It is alleged that the exporter made false customs declarations purporting to indicate that the cars were destined for non-sanctioned countries, while the investigators determined that the cars were all subsequently registered in Russia.

November 3, 2025November 3, 2025 by Mark Handley

Norway – investigation into alleged military technology exports to Russia

After press reporting on possible breaches of Norway’s Russian sanctions by companies in the Kongsberg Group, the Public Prosecutor’s Office has confirmed that as of 25 October, it had started an investigation:

“PST has today decided to initiate an investigation of Kongsberg Discovery for violation of export control regulations. The reason for our decision is that through media coverage in recent days, information has emerged that gives PST reason to carry out further investigations“.

Kongsberg is a state-owned arms manufacturer and is reported to have stated to the press that it has followed Norway’s regulations.

The allegations are that equipment used for undersea surveillance have been sold and shipped to Russian military customers.

October 31, 2025 by Mark Handley

Czechia – criminal prosecution for dealing with designated person’s funds

Recent reporting on a Swiss judgment has thrown light on an ongoing criminal prosecution for alleged sanctions breaches being undertaken in Czechia.

The investigation resulted in the commencement of a criminal prosecution in August 2023 against Dmitry Kalantyrsky who is alleged to have dealt with a designated person’s frozen assets in 2015.

In October 2024 it was reported that the Czech Constitutional Court had dismissed a complaint brought against the prosecution, with the report noting that the allegations involve funds valued at approximately €4m, and that the designated person in question is alleged to be Arkady Rotenberg.

October 29, 2025October 29, 2025 by Mark Handley

Estonia – 2 year sentence for sanctions offences upheld on appeal

The Tallin Circuit Court has denied an appeal from Svetlana Burtseva against a conviction for sanctions and treason offences.

As per our earlier post, Burtseva has been sentenced to 6 years in jail, of which 2 years were for the sanctions offence.

The sanctions offence was the making of economic resources available to a sanctioned person. Ms Burceva worked for Russian state media outlet RIA Rossiya Segodnya, the head of which is Dmitry Kiselyov who is sanctioned by the EU.

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.