Infrastructure and Transport (including energy) – European Sanctions Enforcement

December 23, 2025December 23, 2025 by Mark Handley

Sweden – Customs board distressed Russian vessel in Swedish waters

After a Russian vessel had engine trouble and entered Swedish territorial waters, Swedish Customs boarded the vessel and commenced an investigation into whether possible sanctions or export control offences may have been committed.

The vessel, the Adler, is designated under EU sanctions, and the owner sanctioned by the US. It is reported that the cargo included arms and military equipment.

It is now being reported that the vessel has been allowed to depart Swedish waters, after the Prosecutor’s Office declined to open a criminal investigation, on the basis that there was no intent to being the vessel or its goods into Sweden.

December 3, 2025December 3, 2025 by Mark Handley

Germany – investigation into businesses alleged to have exported €10m in luxury cars to Russia

It is being reported that the Munich Prosecutor’s Office is investigating a number of businesses suspected of exporting 50 luxury cars to Russia in breach of the EU’s sanctions.

The cars are said to be valued at €10 million, including one car fitted with armour valued at €650,000.

The report alleges that the exports were done via third countries including Kazakhstan.

November 25, 2025November 25, 2025 by Mark Handley

Netherlands – trial commenced of shipbuilder for sanctioned exports to Russia

Further to our earlier post, the prosecution trial of Damen Shipping has commenced in the Netherlands.

The company has denied the allegations, which include that it falsified customs declarations to enable the export of 14 deck cranes to Russia during 2022 in breach of the EU’s sanctions.

Senior management have also been charged with sanctions offences.

The trial includes charges of bribery against Damen.

November 21, 2025November 25, 2025 by Mark Handley

Germany – raids in relation to export of hundreds of luxury cars to Russia

It is being reported that seven residential and commercial premises in the Steinfurt area were raided on 20 November by Customs officers from Essen, Münster and Osnabrück.

The raids relate to allegations that three individuals (aged 57, 32 and 27) were involved in the export of 346 luxury cars to Russia via third countries in breach of the EU’s sanctions.

The exports are said to have taken place between 2022 and 2024 and have totalled approximately €20m in value.

The report adds that assets (including real estate, cars and bank accounts) valued at €20m have been seized as part of the investigation.

November 20, 2025November 20, 2025 by Mark Handley

Sweden – Swedish Customs sanctions enforcement

The Swedish Police have issued a report on sanctions compliance in the country, concluding that trade flows to countries neighbouring Russia suggests Swedish involvement in the circumvention of the EU’s sanctions.

In relation to the work of Swedish customs, the report noted that in 2023 more than 200 export shipments were stopped, and that 3,000 export declarations in 2024 were “subject to special review measures”.

The press release to the report notes that “a handful of preliminary investigations [are] underway regarding sanctions violations at the Police Authority and at Swedish Customs”.

The report also highlights an earlier 2024 report by the Swedish Financial Supervisory Authority on the outcome of its review of the sanctions screening processes and methodologies of 19 banks operating in Sweden. The report noted that none of the banks assessed had good enough automatic screening in place, but that the larger banks were better at screening than the small and medium sized banks.

November 19, 2025 by Mark Handley

Germany – sanctions trial begins of individuals suspected of exporting €28m in luxury cars

The trial has commenced in Berlin of Evgeniya P., Wladimir K. and Ekaterina M. Only Evgeniya P. is before the court, the others are being tried in absentia.

The three are alleged to have exported 257 luxury cars to Russia in breach of the EU’s sanctions with a value of €28.2m.

The exports are reported to have been completed via Belarus, Kyrgyzstan, Kazakhstan or Turkey.

November 10, 2025 by Mark Handley

France – extradition to the US to face Russian export charges

On 4 November, the US Justice Department issued a press release following the extradition from France of Yana Leonova to face charges of exports of aviation equipment to Russia in breach of US sanctions.

The press release gives little information on when she was arrested or whether the extradition was contested.

It is alleged that she falsified the final destinations for exports and used a variety of front companies in Armenia, the Maldives and elsewhere.

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.

October 29, 2025October 29, 2025 by Mark Handley

Estonia – investigation into bunkering company suspected of sanctions breaches

It is being reported that the Estonian Prosecutor General’s Office has been investigating a bunkering company for alleged breaches of the EU’s sanctions in relation to Russian oil.

The report states that raids were conducted in 2023 on the company NT Bunkering, with evidence and property seized.

In response to a question from LRT, the Prosecutor General’s Office stated that a pre-trial investigation remained ongoing and could not otherwise comment.

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.