European Sanctions Enforcement

May 19, 2026May 19, 2026 by Mark Handley

UK – OFSI fines bank £165,000 for processing transfers to an entity wholly-owned by designated person

The UK’s Office of Financial Sanctions Implementation has issued a Penalty Notice against the London branch of Deutsche Bank AG fining it £165,000.

The fine related to two payments made in June 2022 and July 2022 that had been voluntarily reported to OFSI in September 2022. The “pace” of resolving this matter is in keeping with previous cases from OFSI.

The first payment leading to the fine was of £356,429.27 processed on 29 June 2022 in favour of a company called Okko LLC. Earlier that same day the UK had designated the 100% shareholder of Okko, JSC New Opportunities.

The second payment of £279,189.48 was made a month later.

OFSO took the view (particularly in light of the second payment) that even though there had been a limited window to stop the first payment, nonetheless there was such a window. The screening methods used by Deutsche Bank failed to identify that a newly-designated entity wholly-owned the intended transferee. This failing continued for the next month and was not purely a function of the short window for the first payment.

OFSI also took the view that the breaches could only be seen as such after the UK adopted a strict liability rule for the civil enforcement of sanctions breaches on 15 June 2022. An additional payment made before this date, was not considered a “breach” for this reason.

The notice was resolved under OFSI’s new settlement regime, and involved a 45% discount on what would otherwise have been a £300,000 fine based on the self-disclosure and Deutsche Bank agreeing to settle.

May 18, 2026May 18, 2026 by Mark Handley

Sweden – further arrest relating to the detention of the oil tanker “Sea Owl I”

Further to our earlier post from March regarding Sweden’s seizure of the Sea Owl I, Sweden’s Coast Guard has issued an update.

At the time of the seizure the flag was purporting to be Comorian flagged, but the Swedish authorities doubted the validity of that registration.

Following the seizure the vessel purported to re-register with another flag state. The Coast Guard’s update is reporting that a second crew member has now been arrested on suspicion of using false documents relating to the purported re-registration of the vessel.

May 18, 2026May 18, 2026 by Mark Handley

Switzerland – investigation into financial sanctions circumvention

As part of the Annual Report for 2025, Switzerland’s Federal Police Agency (Fedpol) has included information on an investigation into Russian funds held by an unidentified sanctioned Russian oligarch (the report uses the name “Aleksandr*” but this is not the person’s real name.

The report makes mention of a number of suspicious activity reports filed by Swiss private banks, and cooperation with an unnamed foreign country led to a significant investigation:

“The investigation revealed that Oleg and Dimitri owned assets in several cantons. The competent foreign criminal prosecution authority submitted a request for mutual legal assistance to the Federal Office of Justice with the aim of searching the premises and seizing the assets of Oleg and Dimitri, in particular bank accounts and real estate. A cantonal public prosecutor’s office was responsible for processing the request for mutual legal assistance. fedpol coordinated the case in Switzerland and abroad. By the end of 2025, the operation was underway, with more than 50 Swiss investigators and prosecutors from several cantons involved.

The seizures would first take place in Switzerland, with further actions in other European countries scheduled to follow. To this day, this remains one of the largest cases involving money laundering for the purpose of evading sanctions“.

The report does not discuss the outcomes of the investigation so far.

May 11, 2026May 11, 2026 by Mark Handley

Sweden – raids and two arrested as part of Russian sanctions breach investigation

The Swedish Security Service has issued a press release confirming raids on multiple residential properties in southern and western Sweden, as well as the arrest of two individuals suspected of gross violations of the EU’s sanctions against Russia.

The breaches are said to relate to the “procurement of advanced products on behalf of Russia” but no further detail has been provided at this stage.

May 8, 2026May 8, 2026 by Mark Handley

Latvia – sanctions enforcement data from Customs for the first quarter of 2026

A few weeks ago, Latvia’s Customs Service published data on its sanctions enforcement actions for the first quarter of 2026.

This includes:

161 shipments destined for prohibited export to Russia and Belarus were stopped;
26 shipments intended for prohibited import from Russia and Belarus were stopped;
43 attempts to export cash to Russia were prevented;
42 cases of violation by individuals using the postal service;
29 administrative proceedings were commenced for violations of sanctions; and
18 cases were referred to initiate criminal prosecutions.

May 8, 2026May 8, 2026 by Mark Handley

Poland – publication of sanctions enforcement statistics including 138 fines imposed

The government of Poland has issued a press release detailing its efforts to date on the enforcement of the EU’s sanctions against Russia and Belarus.

My thanks to Dr Marcin Lukowski for drawing this release to the blog’s attention.

To date Poland has:

imposed fines of PLN 74.4m (c. €18m) across 138 separate fining decisions; and
in the first quarter of 2026 there are:
- 191 pending cases;
- 122 cases where an individual has been identified as a suspect (“charged” in Polish terminology);
- 13 indictments filed; and
- 10 final judgments.

The government also states that it has frozen €546.2m in assets, and that nearly 56% of all EU customs alerts originate from Poland.

As per our earlier post from September 2025 – at that stage Poland had imposed 42 fines for a total of PLN 26.6m or €6.2m, meaning the number of fines, and the value of fines imposed, has nearly tripled since September last year.

May 6, 2026May 6, 2026 by Mark Handley

Netherlands – confiscation orders issued against company and individual convicted in 2024 of sanctions offences

Further to an earlier post relating to convictions of an individual and company obtained in October 2024 for supplying aircraft parts to Russian customers in breach of the EU’s sanctions, the Rotterdam Court has now ruled in the confiscation proceedings brought by the prosecution.

In the confiscation judgement against the (unnamed) company, the court ordered the confiscation of €165,826.

The court held that the revenue obtained from the sanctions breaches was €2,901,194, but allowed as “deductible costs” 82% of this amount, or €2,385,739. This is in line with the Dutch approach of allowing the convicted parties to break even on the unlawful transactions by confiscating not the illegally-obtained revenue (which the CJEU has held is a permissible approach), but rather the pure profit element.

The profit element was accordingly assessed as €515,455 which was divided between the convicted person and the convicted company.

In the second confiscation judgment against the individual, the same analysis was undertaken with the balance of €349,629 from the profits attributed to the individual. The judgment states that a further 599 days of jail time would be added to the existing sentence in the event that the confiscation order is not satisfied.

May 5, 2026May 5, 2026 by Mark Handley

Denmark – company self reports to Danish Business Authority for possible sanctions breaches

Danish company FLSmidth & Co A/S has issued a press release stating that it has self-reported the outcome of an internal investigation to both OFAC and the Danish Business Authority and will cooperate with the authorities.

The press release states that the internal investigation ” identified information indicating that certain pre-contract tender materials have been provided to persons in the Russian Federation in connection with a limited number of potential projects in Kazakhstan”.

The press release adds that as a result of the internal investigation the company is “in the process of reviewing and enhancing its compliance programme and risk management measures as well as other mitigating action”.

May 5, 2026May 5, 2026 by Mark Handley

Sweden – Chinese captain of Syrian-flagged ship the Jin Hui arrested and ship detained

On Sunday Sweden’s Prosecutors announced the arrest of a Chinese national who was the captain of the Syrian-flagged vessel suspected of belonging to the Russian shadow fleet, the Jin Hui.

The particular offences forming the basis for the captain’s arrest are the use of false documents and suspected violations of the Maritime Act in relation to seaworthiness.

The vessel is reported to have been in Swedish territorial waters at the time it was detained and is now anchored off Trelleborg.

May 5, 2026May 5, 2026 by Mark Handley

Sweden – Prosecutors seize cargo vessel and seek confiscation

Further to our earlier post regarding the boarding and capture of a cargo vessel, the Caffa, the Swedish Prosecutor’s Office has announced that the vessel has now been formally seized the vessel “in order to obtain a judicial review of whether the vessel can be handed over to the state”.

Press headlines that the vessel has already been fully confiscated appear to be overstating the current position.

The press release adds that the investigation involves a request for mutual legal assistance from another state, but that state is not named. The vessel is suspected of having been carrying stolen Ukrainian grain and to have been sailing under false flag documentation.