Technology and Telecom – European Sanctions Enforcement

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.

February 25, 2026February 25, 2026 by Mark Handley

Poland – six individuals charged with exporting drone-making machinery to Russia

Poland’s Internal Security Agency has issued a press release announcing that six individuals have been charged on suspicion of exporting machinery for the manufacture of drones to Russia, via Belarus, in breach of the EU’s sanctions.

The charges follow raids conducted on 18 February.

The individuals include 4 Belarus nationals and two Poles, and the machinery is described as a device for the production of integrated circuits.

Three of the suspects have been ordered to remain in custody, while the other three were released on bail subject to supervision and a ban on leaving Poland.

February 13, 2026February 13, 2026 by Mark Handley

Latvia – prosecution for providing IT services to Russian company

The State Security Service of Latvia has announced the prosecution of an individual for providing programming services to a Russian company.

This is the fifth recent prosecution in Latvia either in relation to the provision of prohibited services under Regulation 833/2014, or the provision of services to a designated person with the services treated as an “economic resource” that breaches the imposed asset freeze (see October 2025, October 2025, December 2025, and December 2025).

The individual is also being prosecuted on the basis that his salary was paid into Alfa-Bank, which is a designated person under the EU’s sanctions, and that this constitute making funds available to that designated person.

February 4, 2026February 4, 2026 by Mark Handley

United Kingdom – investigations into possible breaches of the Cyber sanctions regime

It is being reported, following a Freedom of Information request to HM Treasury, that the UK’s Office of Financial Sanctions Implementation has between 1 and 5 investigations ongoing in relation to possible breaches of the asset freezes imposed by the UK’s Cyber sanctions regime.

The breaches are all said to relate to the financial services sector, but no further information was released so as to not prejudice ongoing or future investigations.

The report notes that an earlier Freedom of Information request was refused but an internal review lead to the release.

December 23, 2025 by Mark Handley

Lithuania – raids as part of investigation into sanctioned exports to Russia and Belarus

It is being reported (here and here) that Lithuania’s Financial Crime Investigation Service and the State Security Department, with coordinating assistance from the European Public Prosecutor’s Office, are undertaking an investigation into suspected breaches of the EU’s Russian and Belarus sanctions by Lithuanian, Russian and Belarus individuals.

It is alleged that those involved forged documents to obtain funding from the EU Space Agency, and that the money was then used (with other funds) by a company incorporated in Lithuania to obtain and export microchips, semiconductors, navigation systems, and other technical devices to Russia and Belarus.

In total 10 raids were conducted, and 5 individuals and one company are under investigation.

November 10, 2025November 10, 2025 by Mark Handley

Estonia – arrest and pre-trial detention for sanctioned media offence

A court in Estonia has remanded an individual, Oleg Bessedin, in custody for two months while he awaits trial.

The prosecution is for a number of offences including allegedly breaching prohibitions in relation to the dissemination and broadcast of content from designated Russian media outlets under the EU’s sanctions.

The man denies the charges, but has been remanded due to perceived fight risk.