European Sanctions Enforcement

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 22, 2025October 27, 2025 by Mark Handley

Denmark – engineering company to plead guilty to Russian sanctions breach

It is being reported (behind a paywall) that Danish engineering company Alfa Laval will plead guilty to a violation of the EU’s sanctions against Russia at a hearing due to take place later this week.

Reporting states that the company has ascribed the breaches to “human error”.

The press is citing an expected corporate fine of DKK 100,000 (€13,300), but is unclear if this has been the subject of an agreement.

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 20, 2025 by Mark Handley

Finland – suspended sentence on conviction for dual-use exports to Russia

It is being reported, that after pleading guilty to charges of exporting dual-use goods to Russian in breach of the EU’s sanctions, a 20-year old student has been given a 14-month suspended sentence.

The student exported dual-use drones, laptops, computer processors, smartphones and laser rangefinders valued at nearly €74,000.

Further to our earlier post, two other accomplices were also arrested in May 2024 and have been investigated for exports valued at another €70,000.

As well as pleading guilty the student is said to have co-operated with the investigation. The outcome relating to the other two defendants is not yet known.

October 20, 2025October 20, 2025 by Mark Handley

Germany – hearing begins for confiscation of €720m from sanctioned Russian bank

Further to our earlier post, it is being reported that the confiscation proceedings are now ongoing in the Frankfurt Higher Regional Court seeking to confiscate €720 million as the proceeds of crime from a sanctioned Russian bank.

According to reports the Russian bank sought to transfer these funds out of Germany in the immediate wake of being designated by the EU in June 2022, but the banks asked to process the payments refused to proceed.

As funds transferred in breach of the asset freeze imposed on the bank, these funds have been characterized by the prosecution as the proceeds of crime and so subject to confiscation under applicable anti-money laundering laws.

The case is being heard before a five judge bench.

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.

October 9, 2025 by Mark Handley

Portugal – investigation into possible sanctions breaches by professional football team

It is being reported that the Portuguese authorities have commenced an investigation into possible sanctions breaches by the football team Benfica.

The allegations relate to player transfers and payments between Benfica and the Russian club Lokomotiv Moscow, which is owned by the sanctioned Russian state-owned railway company RDZ.

The manager of Benfica, Rui Costa, is due to be questioned as part of the investigation.