Belarus – European Sanctions Enforcement

May 1, 2026May 1, 2026 by Mark Handley

Germany – publication of the latest 6-monthly sanctions enforcement update

The German authorities have published the third instalment of their 6-monthly updates on their current enforcement actions.

The report highlights:

The conviction on 2 March 2026 of two individuals relating to the export of 111 luxury cars to Russia, with €20m confiscated, and jail sentences of 6 years and 2 years (the latter suspended). See our previous post.
Raids conducted in November 2025 and the ongoing investigation into the suspected export of machine tool to Russia value at €1.7m. The report confirms that the investigation by the Stuttgart Public Prosecutor’s Office and the Stuttgart Customs Investigation Office remains ongoing. See our previous post.
An investigation into five suspects for the organized circumvention of sanctions against Russia. A company is alleged to have exported technical equipment and accessories worth c. €689,000 to a company in Russia via third countries. The investigation started in February 2025 and is being conducted by the Essen customs investigation office, is ongoing. See our previous post.
The prosecution of a 41-year old suspected of exporting 236 cars to Russia valued at approximately €18.86m. See our previous post.
The arrest of five suspects on 2 February suspected of 16,000 illegal deliveries to 24 listed Russian arms companies of good worth at least €30m. The prosecution was supported by the Federal Intelligence Service (the BND). See our previous post.
On 27 March raids conducted on 14 premises in the Rhine-Main region against two companies suspected of exporting machine parts and chemicals to Russia. A third company is said to have been involved in the alleged use of a transport and logistics companies to try and circumvent the EU’s sanctions. See our previous post.
The ongoing investigation into a member of the Saxon state parliament for allegedly falsifying the export declaration in relation to a telescopic handler rather than stating the correct destination of Belarus. Searches were conducted at residential and business premises. See our earlier post.

The update also reports on a decision of the CJEU from 5 February 2026 upholding the seizure by German customs of a Mercedes car purchased in Russia and imported to Germany. The CJEU held that the single specific import did not need to “generate significant revenue for the Russian state”, so long as the general category of goods did.

Further cases noted previously in the blog over the last few months, but not included in the report are:

an investigation from February 2026 in relation to the import of goods valued at over €4m from Russia;
an investigation made public in January 2026 into the use of RussPost to export goods to Russia;
reporting from January 2026 into a mutual legal assistance request made to Ukraine as part of an investigation into the suspected export of drone parts to Russia;
the arrest in January 2026 of two people on suspicion of making available funds and economic resources to the Donetsk and Luhansk People’s Republics;
an investigation made public in December 2025 by the Munich Prosecutor’s Office into alleged export of 50 luxury cars valued at over €10m; and
raids in November 2025 in relation to the suspected export of 346 cars to Russia.

February 4, 2026February 4, 2026 by Mark Handley

Germany – state parliamentarian arrested for suspected Belarus export

Further to our earlier post from 2024, the Leipzig Public Prosecutor’s office has arrested Jörg Dornau, who is a member of state parliament, on suspicion of breaching the EU’s sanctions against Belarus.

The previous obstacle to his prosecution, parliamentary immunity, has been lifted.

It is alleged that he falsified a customs declaration in 2022 indicating Kazakhstan was the destination of the export of a telehandler vehicle, when the real destination was a company in Belarus.

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

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 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.

December 23, 2025 by Mark Handley

Lithuania – raids as part of investigation into sanctioned exports to Russia and Belarus

It is being reported (here and here) that Lithuania’s Financial Crime Investigation Service and the State Security Department, with coordinating assistance from the European Public Prosecutor’s Office, are undertaking an investigation into suspected breaches of the EU’s Russian and Belarus sanctions by Lithuanian, Russian and Belarus individuals.

It is alleged that those involved forged documents to obtain funding from the EU Space Agency, and that the money was then used (with other funds) by a company incorporated in Lithuania to obtain and export microchips, semiconductors, navigation systems, and other technical devices to Russia and Belarus.

In total 10 raids were conducted, and 5 individuals and one company are under investigation.

September 24, 2025September 24, 2025 by Mark Handley

Poland – 20 people detained for alleged luxury car exports to Russia and Belarus

Poland’s Central Bureau of Investigation of the Police has issued a press release relating to the arrest of 20 people for alleged involvement in a scheme to export of approximately 600 luxury cars to Russia and Belarus in breach of the EU’s sanctions.

The scheme is said to have involved a sequence of sales within the EU, followed by sales to customers in third countries such as Kazakhstan and Azerbaijan, followed by a further transfer to Belarusia or Russia.

Several of the defendants are being detained in custody while the investigation continues.

More than PLN 10m in bank accounts have been frozen as part of the investigation.

September 22, 2025September 22, 2025 by Mark Handley

Poland – updated statistics on the 42 imposed sanctions fines

With grateful thanks to the Ministry of Finance and the Economy in Poland for the provision of the information, this blog can provide an up-to-date summary of the scale of financial penalties imposed by the Polish authorities in relation to Russian and Belarusian sanctions violations.

These figures relate to the period up to 28 August 2025.

In total the Polish authorities have imposed 42 financial penalties, broken down on the following basis:

24 penalties in relation to breaches of EU Regulation 833/2014, with total fines of PLN 6,850,949 (just over €1.6m);
6 penalties for breaches of EU Regulation 269/2014, with total fines of PLN 911,515 (just over €213,000);
10 penalties for breaches of the Polish Sanctions Act of 13 April 2022, with total fines of PLN 18,886,441 (€4.42m);
1 penalty under EU regulation 765/2006 in relation to Belarus, with a fine of PLN 7,367 (€1,727); and
1 penalty relating to both Regulations 833/2014 and 765/2006, with a fine of PLN 36,272 (€8,506).

This updates the statistics previously published on this blog from July 2024.

It shows that Poland has imposed a 18 fines since that time. Of those 12 were under Regulation 833/2014, four were under Regulation 269/2014, and the two smaller fines relating to Belarus have also been imposed since July 2024.

August 27, 2025August 27, 2025 by Mark Handley

Latvia – investigations into sanctioned Belarusian urea imports

It is being reported that the Latvian authorities have been conducting multiple investigations into suspected imports of urea from Belarus in breach of the EU’s sanctions.

The investigations are reported to be focussed on four Latvian companies and were commenced in July.

After a referral from the Customs Administration the VID Tax and Customs Police Department initially declined to prosecute, but that decision is now the subject of an appeal brought by the Customs Administration and Latvia’s FIU.

May 21, 2025May 21, 2025 by Mark Handley

Poland – seizure of 5 tons of aviation tyres bound for Russia/Belarus

Poland’s National Tax Administration has issued a press release, announcing the seizure of 5 tons of aviation tyres.

The discovery was made through a routine inspection of a truck by the Lublin Customs and Tax office.

The declared goods were automobile tyres. The sender of the tyres was an unnamed company in Spain, and the declared recipient was said to be in Azerbaijan.

The goods were detained and criminal proceedings have been instituted.