European Sanctions Enforcement

June 30, 2025June 30, 2025 by Mark Handley

United Kingdom – prosecution for exports of military goods to Iran, Libya, South Sudan, Sudan and Syria

As first reported by Global Investigations Review (behind a paywall), the UK is prosecuting two individuals for the suspected export of military goods to a range of countries including Iran, Libya, South Sudan, Sudan and Syria.

The defendants David Greenhalgh, 67, and Christos Farmakis, 47, pled not guilty to 17 charges at Southwark Crown Crown on 13 June.

The exports are said to have taken place between 2009 and 2016, with the prosecution underscoring the absence of limitation periods in the UK.

As stated by GIR:

“The defendants allegedly helped ship fighter jets, radar systems, missiles and ammunition to Libya; “battle tanks and associated spare parts”, AK-47 rifles, anti-tank missiles and ammunition to South Sudan; missiles, launchers and rocket-propelled grenades to Syria; and Pechora S-125 surface-to-air missile systems, radar equipment and MiG-29, Su-25 and Su-27 fighter jets to Sudan. …

Farmakis is further accused of being involved in the illicit supply of 5,500 AK-47 rifles and 100,000 tonnes of ammunition to Syria, as well as 25,000 pistols to an unnamed country and unspecified quantities of AK-47 rifles to South Sudan and Iran.

Greenhalgh is separately accused of helping to export Mi-24V attack helicopters to Sudan”.

Trial has been set for April 2026.

June 30, 2025June 30, 2025 by Mark Handley

Italy – seizures against Iranian company associated with Russia

It has been reported (here and here), that in early June the Italian police conducted seizures in Milan against the “Iranian” company Irital Shipping Lines.

The seizures involved assets of over €1m.

The reported reason was “Iran’s military support for Russia’s aggression against Ukraine”.

No public statement has been made by the Italian authorities, and it is unclear what is the precise nature of the allegations.

June 30, 2025June 30, 2025 by Mark Handley

Czechia – investigations announced into 12 companies suspected of sanctioned exports to Russia

After press reporting by The Insider, into the acitivties of Czech companies allegedly exporting to Russia, it has now been reported that the Czech authorities are undertaking investigations into the companies.

The exports of machinery and duel-use goods (valued at more than €10m) are said to have largely gone through a range of third countries such as Estonia, Serbia, Turkey, and Latvia.

Confirmation of the investigations came from Czech Foreign Minister Jan Lipavský and Minister of Industry and Trade Lukáš Vlček.

The companies under investigation are:

Šmeral Brno
Varnsdorf
TAJMAC-ZPS
Pilous-Pásové Pily
Jihostroj a.s.
N.Ko
Prestar
Tachtech s.r.o.
Stroje Zeman Trade
Permico s.r.o.

June 30, 2025June 30, 2025 by Mark Handley

United Kingdom – conviction for sanctioned person failing to provide financial information

Global Investigations Review (behind a paywall) has reported on the conviction in the UK of Aozma Sultana.

As previously posted, the UK’s Charity Commission has started an investigation into Aozma Sultana in April 2024. She was designated under the UK’s post-Brexit terrorism sanctions.

She answered “do not remember” to most of the questions sent to her upon her designation, and did answer the requisite questions on three other occasions – twice more when OFSI chased for responses, and again after he arrest.

Sentencing is to take place on 6 August.

June 30, 2025 by Mark Handley

Finland – Customs investigation into suspected electronics exports to Russia

On Thursday Finland’s Customs announced details of an ongoing investigation into a suspected aggravated offence of breaching the EU’s sanctions. This is the most serious category of offence under Finnish law.

Customs are investigating a company from eastern Finland alleged to have sold electronic parts and components (semiconductors, microchips, processors and connectors) to Russia valued at approximately €2.7m.

The two main suspects are a father and son, with the son currently serving in the Russian army.

The products are alleged to have been shipped via several different routes including via other EU countries, Hong Kong, direct to Russia, and others seemingly collected in Finland.

A tax investigation is also under way.

Prior to 2022 the company’s business is said to have been dedicated to tourism and the sale of art.

June 25, 2025June 25, 2025 by Mark Handley

United Kingdom – law firm fined £600 for breach of Russian sanctions licence conditions

The Solicitors Regulation Authority (the “SRA”) has fined Steptoe International LLP £600 and given the firm a “rebuke” for breaches of the UK’s Russian sanctions.

The breaches are reported to have related to two clients, and involved non-compliance with the conditions of relevant licences granted by OFSI, which is a criminal offence. It is unclear whether this was a general licence or a specific licence.

The firm self-reported the breaches to the SRA, which accepted that the breaches were the result of “inadvertent human error”.

The report makes no mention of any involvement by OFSI.

June 18, 2025 by Mark Handley

Portugal – court judgments reveal ongoing Russian sanctions investigations for breaches of bank deposit cap

In a first for this blog, we can report on sanctions enforcement activity in Portugal.

Three judgments from the Lisbon Court of Appeal reveal ongoing investigations into alleged breaches of the EU’s regulation 833/2014.

The judgments are each the dismissal of appeals by anonymised persons who have had bank accounts frozen pending the outcome of the the criminal investigations in question. In each case the investigation appears to be focussed on alleged breaches of regulation 5b of 833/2014 and the €100,000 deposit cap first introduced in February 2022.

The judgments are from:

a) 24 May 2023: in this case it is alleged that a Russian national (named only as YS) transferred over €1.8m for the purchase of real estate in Portugal in February and June 2022. The judgment mentions that YS had been a senior manager within Gazprombank.

b) 6 February 2025: in this case it is alleged that two Russian nationals (named only as AA and BB) transferred $6m from accounts in Russia and Austria in February and October 2022, and another €4.7m in February and March 2022 There is also an allegation that the transfers related to Tatyana Golikova, who is a designated person under the EU’s sanctions.

c) 11 March 2025: in this case it is alleged that two Russian nationals residing in Russia (named only as AA and BB) transferred several hundred thousand euros to bank accounts in Portugal.

June 18, 2025June 18, 2025 by Mark Handley

Spain – arrests and detentions for the export of prohibited machinery to Russia

It is being reported that as part of a joint investigation by the General Information Commissariat, the Customs Surveillance Directorate of the Tax Agency, and the National Intelligence Centre that a raid was conducted in 10 June in the town of San Vicente del Raspeig in Alicante and three individuals have been arrested.

Following a hearing on Friday two of the arrested were imprisoned pending investigations and the third individual has been released.

It is alleged that an unnamed company exported machinery “mainly used in mass production industries, such as the automotive metallurgical industry, the aerospace industry, or also in the military industry“. It is alleged that the exports to Russia were conducted through third countries, that customs data was falsified, and that the end customer was a designated person under the EU’s sanctions.

The machinery is reported to have been valued at hundreds of thousands of euros.

June 11, 2025June 11, 2025 by Mark Handley

Sweden, Estonia and Lithuania: investigations opened into funding provided by Russian designated person

Further to our earlier post regarding an investigation in Latvia into the activities of the designated Russian state entity “Pravfond”, it has now been reported that a number of other investigations are ongoing in relation to this entity’s activities:

1) An investigation has been commenced in Sweden in relation to a school that had associations with Pravfond;

2) In Estonia a multiple investigations (by the criminal authorities and the bar association) have been opened in relation to lawyers who accepted funds from Pravfond; and

3) In Lithuania a criminal investigation has been opened (as well as one by the bar association) into lawyers who took funds from Pravfond.

June 11, 2025June 11, 2025 by Mark Handley

Netherlands – DNB issues instruction to trust office regarding sanctions compliance

The Nederlandsche Bank (DNB) has issued a press release relating to Erez Corporate Service B.V.

Erez was issued an “instruction” in June 2021 by the DNB in relation to the remediation of various compliance failings, including compliance with EU sanctions.

Erez has sought to challenge, and then appeal, this instruction, but those efforts have not been successful which is why the DNB are now publishing the details of the instruction.