Lithuania – sanctions enforcement statistics and €6.2m in fines for 2025

Lithuania’s Financial Crimes Investigation Service has issued a summary of its work for 2025, as well as a more detailed report (see pages 45-46) that includes the following:

  • 232 suspicious activity reports from financial institutions related to suspected breaches or circumvention of sanctions;
  • 77 of these were reported to other competent bodies in Lithuania or in other EU member states;
  • 45 inspections from the International Sanctions Implementation Commission;
  • €6,236,375.46m in fines for 2025 across 12 cases;
  • In addition:
    • in 2025, 27 cases were dealt with administratively with fines in these minor cases totalling more than €32,150
    • in 2024, 19 cases were dealt with administratively with fines totalling €28,000
    • in 2023, 12 cases were dealt with administratively (the value of the fines is not given)

The report also notes that 1 of the cases related to public procurement, 1 to the failure to provide information, 5 to circumvention, and 20 to the use of a bank designated by the EU.

Poland – sanctions enforcement statistics with nearly 2500 cases registered

A lengthy article in the Belarusian Investigative Center on alleged sanctions circumvention regarding Belarusian wood pellets, includes data obtained from the Polish Prosecutor’s office on sanctions enforcement:

  • 187 criminal cases were pending as of mid-2026 for circumvention of sanctions against Belarus and Russia (see our earlier post from May 2026 where the figure was 191);
  • nearly 2,500 sanctions cases have been registered;
  • 85% of these 2500 cases, or over 2100, concerned Belarus; and
  • At least 91 criminal proceedings were specifically related to wood-processing products.

Estonia – sanctions enforcement data since January 2026 for Customs and Tax Board

Collating the outcomes published in the weekly reports by Estonia’s Tax and Customs Board (see our earlier post for the period from 14 October 2025 to 13 January 2026), reveals the following data:

  • 18 fines
  • total fines of €226,669, with most being small and one of €219,210 including confiscation
  • 13 cases referred to misdemeanour prosecution
  • 3 cases referred to criminal prosecution, including one case that resulted in a 1 year jail term, a 3 year ban on entry to Estonia and a €3400 fine
  • 6 cases referred for further investigation.

The weekly reports give details of many other prevented exports and imports where no further action was taken for first time offenders.

Poland – prosecution of group exporting goods to Belarus

It is being reported (here and here) that the Polish authorities have arrested and imposed bail and travel restrictions on several members of a ring suspected of exports of sanctioned goods to Belarus.

Also arrested, and a search conducted at her house, was a Polish Customs official who is alleged to have taken bribes in return for allowing goods to be exported without inspections.

The exporters are said to have used two sets of paperwork, with Polish Customs shown export documents for food and beverage products, and Belarusian customs shown accurate paperwork for the sanctioned spare parts and other engineering products.

The exports are said to have taken placed between June 2025 and April 2026 using the Kukuryki-Kazlovichy border crossing.

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.

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:

  1. 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.
  2. 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.
  3. 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.
  4. The prosecution of a 41-year old suspected of exporting 236 cars to Russia valued at approximately €18.86m. See our previous post.
  5. 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.
  6. 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.
  7. 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.

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.

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

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The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

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