Technology and Telecom – European Sanctions Enforcement

September 9, 2026September 9, 2026 by Mark Handley

UK – HMRC issues £7.4m penalty for supply of goods to Russia

The UK’s HM Revenue and Customs has issued its largest sanctions-related Compound Penalty to date.

The company, Illumina Cambridge Limited, was fined £7,438,840.13 for breaches of the UK’s Russian sanctions.

The published Notice gives limited information on the breaches:

“Between July 2022 and January 2023 Illumina breached regulation 25(1) through their involvement in the supply of sanctioned goods from one overseas company within their corporate group to another overseas company within their corporate group for export to Russia and other destinations“.

Regulation 25(1) prohibits the direct or indirect making available of “restricted goods” or “restricted technology” either for use in Russia, or to a person connected with Russia.

Illumina Cambridge Limited voluntarily disclosed the conduct to HNRC and cooperated with the investigation.

As noted by HMRC “sanctions breaches can occur when UK businesses are involved in supply chains that result in sanctioned goods being supplied indirectly to Russia (or other countries subject to trade sanctions), even when no goods have been exported from the UK“.

This is the third large fine/forfeiture handed out by UK authorities in the last few weeks following the £4.7m fine from OFSI (2 September) and the $5.2m forfeiture from the National Crime Agency (27 August).

September 4, 2026September 4, 2026 by Mark Handley

Luxembourg – investigation into alleged Russian sanctions breaches discontinued

Further to our earlier post regarding a Luxembourg investigation into possible EU sanctions breaches by the company Spacety Luxembourg SA, it is now being reported that the Luxembourg authorities have discontinued the investigation.

A government spokesperson is reported to have stated that the investigation was discontinued after several mutual legal assistance requests had been made, but it is unclear whether these requests were refused, and to which countries the requests were sent.

The company was placed into liquidation in October 2025.

September 1, 2026September 1, 2026 by Mark Handley

Netherlands – confiscation of proceeds from sanctions breaches reduced on appeal

Further to our earlier post regarding a 2024 conviction and confiscation, the Hague Court of Appeal has ruled on an appeal by the convicted defendants on the quantum of the confiscation.

The revenue from the criminal transactions was €1,924,579.20, with the first instance court allowing deductions of costs, to arrive at an initial confiscation order in the sum of €298,310. This was in line with the Dutch methodology of confiscating net profit rather than gross profit.

The defendant raised a number of arguments:

1) that there should be no confiscation;

2) that certain costs (transport, packaging, testing, etc) had been improperly not deducted from revenue;

3) that the value of confiscated goods should be credited in favour of the defendant; and

4) that the defendant did not have the financial means to satisfy the confiscation order.

All of these arguments were rejected by the Hague Court of Appeal. Despite this, the Court reduced the sum to be confiscated to €250,195. The Court provided no reasoning, or basis for, this reduction.

August 24, 2026August 24, 2026 by Mark Handley

UK and Ireland – TikTok self reports possible sanctions breaches

It has been reported, here (behind a paywall), that TikTok Information Technologies UK Limited, has self-reported potential breaches of sanctions both to the UK’s Office of Financial Sanctions Implementation, and to Ireland’s Central Bank of Ireland, as well as to other unnamed regulators.

The information on the self-reporting comes from the most-recently filed company accounts, available from Companies House in England:

No other information is available on the sanctions regime, or regimes, involved, the nature of the potential breaches, or the progress in any regulatory investigations since April.

June 1, 2026June 1, 2026 by Mark Handley

Germany – trial starts of brothers suspected of Russian exports of engineering equipment

On Friday the trail commenced of two brothers suspected of their role in 65 exports to Russia in the mechanical engineering sector said to be valued at c. €833,000.

The brothers were each managing directors of the exporting company.

A separate prosecution is underway against the father.

The exports to Russia were, it is alleged, masked through exports to shell companies in Turkey and Kyrgyzstan.

May 22, 2026May 22, 2026 by Mark Handley

Netherlands – two arrested on suspicion breaching the sanctions on a designated person

The Dutch FIOD has issued a press release relating to the arrest of 59 and 37 year-old men from Amsterdam and the Hague respectively. Three business premises were also raised and searched.

The investigation relates to a web-hosting company founded in 2022 and designated by the EU in May 2025 for its role in the facilitation of “destabilizing activities directed against the European Union, including interference, cyberattacks and the spread of disinformation”. Following the designation the 57-year old set up a new company in the Netherlands which is alleged to have acted as a front for the continuing operations of the sanctioned entity.

A second Dutch company, of which the 39-year old was the sole shareholder and director is alleged to have played a facilitating role in providing interet connectivity.

May 1, 2026May 1, 2026 by Mark Handley

Estonia – individual charged and settlement with a related company as part of Russian sanctions investigation

Further to our earlier post, the Estonian Public Prosecutor has charged Oleg Bessedin on suspicion of:

“transmitting sanctioned Russian TV programs and content via TV and social media channels controlled by him in Estonia and making the sanctioned content available to other channels as well”.

He is also charged with non-violent offences against the independence, sovereignty and territorial integrity of Estonia.

As part of the same investigation, the Prosecutor’s Office reached a settlement with an unnamed legal entity as part of which that entity made a charitable donation of €4000 to a Ukrainian support charity.

May 1, 2026May 1, 2026 by Mark Handley

Latvia – company liquidated and director fined, and second company fined for Russian sanctions breaches

It is being reported that the Latvian authorities have entered into settlement agreements with two companies and a director of one of the companies in relation to resolving prosecutions for breaches of the EU’s Russian sanctions.

The director of the company to be liquidated was fined €10,140 and the second company was fined €17,940.

The first company (unnamed) had accepted an order to ship to Russia Buchholz relays and control relays designed to protect transformers, with a total value of €161,352.

The exporter approached a customs broker (the second unnamed company) to assist with the shipments to Russia. The broker was not told, and nor did it make enquiries, about the prohibited status of the goods.

The shipment did not proceed, but was stopped after an export declaration was made at the Riga Free Port.

April 1, 2026April 1, 2026 by Mark Handley

United Kingdom – Irish subsidiary of Apple fined £390,000 by OFSI

The UK’s Office of Financial Sanctions Implementation has issued a Penalty Notice fining the Irish-incorporated company Apple Distribution International Limited (“ADIL”), £390,000 for breaches of the UK’s Russian sanctions.

ADIL was fined for issuing payment instructions to a UK bank, and for failing to cancel those payment instructions. The two payments in June and July 2022 for a total of £635,618.75 were to Okko LLC, a company wholly owned by the designated person JSC New Opportunities.

OFSI took the view that the instructions issued to a UK bank, and the failure to cancel those instructions, amounted to conduct within the UK for the purposes of the jurisdictional reach of the UK’s sanctions. This is in line with older case law that had established that sending instructions into the UK could amount to an offence within the UK.

ADIL self-disclosed the conduct in October 2022. The Penalty Notice was also arrived at by way of an agreed settlement pursuant to OFSI’s new enforcement procedures.

The penalty is also noteworthy because JSC New Opportunities was designated by the UK at 11am on 29 June 2022. The first payment instruction had been made on 6 June but with a value date of 30 June. The second payment instruction was issued on 30 June with a value date of 28 July 2022.

OFSI took the view that there was a “narrow window” in which the first payment could have been stopped, and that it was an aggravating factor justifying enforcement action that a second payment had been ordered. The Penalty Notice also expressly states that OFSI was relying on the “strict liability” enforcement rules that come into effect in 15 June 2022. Earlier payments made to Okko LLC, while it had been owned by a different designated person were also made in breach of the UK’s sanctions, but were not the subject of OFSI’s enforcement action as they took place before the coming into force of the “strict liability” rules.

OFSI also stated that despite the failings of the external screening provider used by ADLI, it was ultimately ADLI’s responsibility as the payment issuer, to ensure compliance with the UK’s sanctions.

March 18, 2026March 18, 2026 by Mark Handley

Latvia – 11 year jail sentence for exporting Starlink kits to the Russian military

The Latvia Prosecutor’s office has secured a conviction and 11-year jail term against an Azerbaijani national.

Three other defendants (including two Latvian nationals) are to be tried separately.

The man was convicted for his role in exporting dozens of Starlink Mini Kits to the Russian military, as well as “other goods used for military activities, including weapons parts, cartridge shells, bullets, ballistic weather meters, in total worth about 200, 000 euros”.

As well as sanctions offences the man was convicted of being part of an organised group to assist a foreign state in undermining the territorial integrity and independence of a democratic state.

In addition to the 11-year jail term, upon release he will be expelled from Latvia and be subject to a 5-year ban on re-entry.

This is the longest known sentence for breach of the EU’s Russian sanctions.