European Sanctions Enforcement

January 15, 2026January 15, 2026 by Mark Handley

Estonia – Tax and Customs Board sanctions enforcement statistics

As of 14 October 2025, the Tax and Customs Board of Estonia has started to publish weekly summaries of its activity, including the enforcement of sanctions at the various customs points with Russia.

Based on these weekly summaries the identification of a sanctions breach by customs officials results in one of four outcomes: 1) the import/export is prevented without further actins being taken; 2) an investigation is commenced; 3) a criminal proceeding for a misdemeanour offence is started; or 4) an on-the-spot fine is issued.

Based on the weekly reports since mid October, the following enforcement actions in categories 1-3 can be identified:

3 investigations started;
10 criminal prosecutions for misdemeanour offences started;
14 on-the-spot fines, imposed, with values of €120, €304, €600, €1600, €1600, €800, €80, €240, €800, €600, €800, €400, €800 and €2000 (total of €10,744).

The offending is dominated by the small-scale carriage of luxury goods and euro notes.

The weekly summaries that include sanctions enforcement can be found here:

In addition, back on 18 August 2025, the Tax and and Customs Board published a half-yearly sanctions enforcement update – not previously reflected here.

This identified the following enforcement statistics:

585,000 identified border crossings
4,300 sanctions violations detected (said to be down 1,000 from the previous year)
on-the-spot fines of c. €93,000 imposed
413 misdemeanour proceedings initiated
19 more serious criminal proceedings initiated

January 12, 2026January 12, 2026 by Mark Handley

United Kingdom – trial scheduled in prosecution for supplying luxury art work to person connected with Russia

Further to our earlier post, it is being reported that the trial in the UK’s criminal prosecution the art gallery Hauser and Wirth, and shipping company, Artay Rauchwerger Solomons, has been scheduled for January 2028.

The companies are charged in relation to allegedly making a luxury good, a work of art, available to a person connected with Russia.

The next hearing is scheduled for 5 May 2026 at which the defendants will be able to enter their pleas.

January 12, 2026January 12, 2026 by Mark Handley

Latvia – prosecution for ammunition export to Russia

Latvia’s Prosecutor’s Office has issued a press release regarding bringing a criminal prosecution before the Riga City Court against an Estonian-Russian dual national for attempting to transport 10,000 items of ammunition into Russia.

The shipment was stopped at the Terekhov Customs crossing. As part of a search of the truck the bullets were found hidden within the driver’s cab of the truck.

January 12, 2026January 12, 2026 by Mark Handley

Romania – enforcement of travel ban on person designated under EU’s Global Human Rights sanctions

An individual included in the EU’s Global Human Rights sanctions list has been barred from entering Romania and deported.

The press reporting does not name the sanctioned individual, but the reporting indicates the person to have been an Israeli settler.

January 12, 2026January 12, 2026 by Mark Handley

Poland – individual charged for importing inflatable vessel from Belarus

Polish authorities have charged an individual after attempting to import an inflatable vessel into Poland from Belarus.

The individual is a Belarusian national, and the inflatable craft was identified by Polish customs at the Terespol border checkpoint.

January 8, 2026January 8, 2026 by Mark Handley

Luxembourg – CSSF fines bank €185,000 including for sanctions compliance failings

Luxembourg’s financial services regulator, the CSSF, has issued a fine against Rakuten Bank SA for various compliance failings including sanctions and AML.

One of the failings identified was “accumulated significant and recurring delays in processing alerts relating to customer screening against list of persons subject to restrictive measures in financial matters”. The Notice identified a particular example of a customer subject to anti-terrorism sanctions where the review of the alert took more than six months.

Another failing identified was a failure to “apply ‘without delay’ potential restrictive measures in financial matters”.

January 2, 2026 by Mark Handley

Poland – 5 arrested on suspicion of importing sanctioned Russian and Belarusian timber

Poland’s Customs and Tax Service has conducted raids and arrested five individuals suspected of importing Russian and Belarusian birch plywood under falsified papers to make it appear that the timber was of Kazakh or Turkish origin.

The five individuals have been named as:

Franciszek B. (64 years old, Polish citizen)

Marian K. (48 years old, Polish citizen)

Piotr K. (56 years old, Polish citizen)

Aleksander P. (43 years old, Russian citizen) and

Sergey M. (57 years old, Russian citizen).

The imports are alleged to have taken place between 2022 and 2024.

The investigation was aided by materials from OLAF (the European Anti-Fraud Office) and from the response to a mutual legal assistance request provided by Kazakhstan.

The suspects have all been charged but have been release pending trial.

January 2, 2026January 2, 2026 by Mark Handley

Italy – raids and arrests as part of Hamas fundraising investigation

The Guardia di Finanza and Police in Italy have arrested nine people and seized over €8m in assets as part of an investigation into fundraising on behalf of sanctioned group Hamas.

The Guardia di Finanza press release is here.

The investigation was supported by Eurojust and authorities in the Netherlands.

As part of the investigation premises have been searched in Genoa, Milan, Rome, Turin, Bologna, Bergamo, Florence, Monza Brianza, Lodi and Sassuolo, with cash of €1,080,000 seized.

It is alleged that various front organizations raised funds, not for charitable or humanitarian purposes, but to support the military operations of Hamas.

January 2, 2026January 2, 2026 by Mark Handley

Finland – investigation into steel cargo on seized Russian vessel

Finnish Customs are investigating the cargo of structural steel found on board the vessel Fitburg, that has been detained as part of a wider investigation into suspected damage to an undersea cable that runs between Helsinki and Tallinn.

The Russian steel was on board the vessel that departed St Petersburg before the ship was detained. The steel is subject to import prohibitions under the EU’s Russian sanctions.

January 2, 2026January 2, 2026 by Mark Handley

Germany – €10 million payment to settle sanctions investigation into Usmanov

Prosecutors in Germany have settled their investigation and prosecution of Alisher Usmanov for suspected breaches of EU sanctions.

The settlement involves a payment of €10 million but no admission of liability.

The investigation related to allegations of payments made by or on behalf Usmanov, a designated person, in relation the provision of security for two properties in Germany.