Ireland – charges of Russian sanctions breaches not pursued following Gardaí investigations

Ireland’s Gardaí (National Police) have confirmed to Global Investigations Review that it has referred two investigations for prosecution for alleged breaches of the EU’s sanctions imposed on Russian in the wake of the full-scale invasion of Ukraine in 2022.

It was also confirmed that the Public Prosecution Service declined to being charges in both investigations.

One such referral to the DPP was reported to have taken place in April 2023.

In March 2024 it was reported that the Gardaí had four investigations ongoing into suspected Russian sanctions breaches, but the status of those further investigations is unknown.

Netherlands – company settles with prosecution and fined €120,000 for Crimean exports

The District Court in Amsterdam has issued a judgment arising from the export of machinery from the Netherlands to Crimea in 2016 and 2017 for use in the construction of the Kerch Bridge.

The company (a B.V. unnamed in the judgment) reached a settlement with the prosecution, whereby no defence was advanced, no appeal would be lodged, and the company agreed to pay the fine of €120,000.

The court found that the prosecution case was made out, and confirmed the terms of the settlement and the proposed fine.

The judgment does not mention any confiscation of the proceeds of crime.

Judgments have also been released in relation to the related prosecutions of two individuals (here and here), both of whom were acquitted.

Netherlands – arrest of individual for suspected financial sanctions breaches

The Dutch FIOD has issued a press release relating to the arrest of an individual suspected of various offences including unlicensed ‘hawala’ banking and breaches of the Dutch Sanctions Law.

As part of the investigation a residential property was raised and mobile phones and other devices seized.

It is alleged that the suspect was at the centre of a network capable of large-scale financial transfers from the Netherlands to other countries.

Netherlands – company and director suspected of exporting computing equipment to Russia

The Dutch FIOD has issued a press release stating that a 57-year old man has been arrested and that the individual and a company are suspected of exporting US$24 million in computer motherboards and graphics cards to Russian customers in breach of the EU’s sanctions against Russia.

Residential and commercial premises were raided, and bank accounts seized.

The exports are alleged to have been done through Hong Kong, the United Arab Emirates and Cyprus

Spain – five arrested for suspected chemical exports to Russia

The Spanish authorities have issued a press release confirming a series of raids in the provinces of Barcelona and Valencia and the arrest of five people.

The raids and arrests are said to be the second phase of Operation Probirka, the first phase of which was conducted in October 2024 (see our previous post).

The bodies involved were the National Police and the Tax Agency.

The allegations include the use of front companies and dummy intermediaries in Kyrgyzstan and Armenia, and the export of chemicals which can be used in the manufacture of explosives and chemical weapons.

United Kingdom – designated person charged with failing to disclose their assets

Further to our earlier post regarding the UK’s Charity Commission investigating Aozma Sultana in relation to possible sanctions breaches, it has now been reported (first by GIR – behind a paywall), that Aozma Sultana has been charged with sanctions offences in the UK and that she appeared in court last week.

Ms Sultana is a designated person under the UK’s anti-terrorism sanctions.

The alleged offence is one of refusing or failing to comply with a request from HM Treasury for information as to her assets and finances.

Trial is currently set for June 2025.

Germany – investigation into alleged sanctions breaches by Roman Abramovich

It is being reported that investigations have been commenced in Germany in relation to suspected sanctions breaches by Roman Abramovich.

Actions by the Federal Criminal Police Office and the Central Sanctions Enforcement Office have included raids on properties and the confiscation of luxury cars and artwork.

The suspected breaches of Regulation 269/2014 are the failure to properly or adequately disclose his frozen assets, including a 19th-century villa in Garmisch-Partenkirchen

It is also being reported that Mr Abramovich’s lawyer has said that he is not the ultimate owner of the villa or the confiscated luxury cars.

Lithuania – sanctions raids, arrests and seizures related to trucking companies

It is being reported that the Lithuanian Customs Criminal Service has conducted raids at multiple addresses in Vilnius and Rudamina, has arrested four individuals (2 Belarus nationals and 2 Lithuanian nationals), and seized 33 vehicles valued at €1.5 million.

The vehicles are 17 trucks, 15 semi-trailers and a mini-bus, which are said to have been involved in alleged trade with Russia and Belarus in breach of the EU’s sanctions.

The first round of raids were conducted on 29 January with further raids since then.

Estonia – 83 criminal prosecutions for Russian trade sanctions violations since 2024

It has been reported that during 2024 Estonia’s Internal Security Service commenced 71 criminal cases in relation to suspected trade with Russia in breach of the EU’s sanctions, and has commenced another 12 already during 2025. These cases are said to be for the more serious, intentional or repeat offenders.

The same report note that Estonia’s Police and Border Guard Board are currently identifying an average of 12 sanctions violations per day predominantly by individuals attempted to take cash or luxury goods into Russia. This is reported to be down from a previous average of 22 violations per day.

With all people crossing the border being subject to inspection, first time offenders are required to either turn back and not cross, or to accept confiscation of the goods/items and continue the journey.

United Kingdom – OFSI reveals 706 Russian sanctions investigations opened since February 2022

As first brought to wider attention by the Global Sanctions site, the UK’s Economic Secretary has provided a written answer on the UK Parliament’s website to the question: “how many investigations by the Office of Financial Sanctions Implementation into breaches of Russian sanctions (a) are open and (b) have been undertaken since February 2022“.

The answer stated that 388 cases have been investigated by OFSI and closed since February 2022, and that 318 investigations are currently open.

This is a total of 706 investigations opened by OFSI into potential or alleged Russian sanctions breaches in the UK since February 2022.

In that time OFSI has imposed two fines (here and here) in relation to Russian sanctions and disclosed one other breach by Wise Payments Limited (here).

This means that 385 of OFSI’s opened Russian investigations since February 2022 were closed without further action.

As of April 2023, OFSI was reporting it had 172 lives cases ongoing, indicating that there has been a significant increase since then.

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