Dual-Use Goods – European Sanctions Enforcement

October 7, 2026October 7, 2026 by Mark Handley

Romania – investigation into dual-use exports to Belarus via third countries

It is being reported, that Romania’s Directorate for Investigating Organized Crime and Terrorism (DIICOT) is investigating the company World Machinery Works S.R.L. and two of its senior managers on suspicion of export of dual use goods to Belarus in breach of EU sanctions.

The attempted exports were in two parts valued at €980,000 and €1.75m and are suspected of being destined for BelAz Holdings in Belarus.

The machine tools were initially exported to Germany. One remains there, the other got as far as Kazakhstan before being stopped. It had been routed via Germany, Austria, Turkey, Georgia, Azerbaijan and then Kazakhstan with the alleged destination being Belarus.

The report notes that several of the suspected individuals have already admitted involvement.

September 29, 2026September 29, 2026 by Mark Handley

Netherlands – raids and arrests in investigation into suspected IT services and high-tech exports to Russia

The Dutch Openbaar Ministerie has issued a press release relating to raids and arrests conducted by FIOD today.

Two individuals, a 52-year old Russian and a 50-year old Dutch national were arrested and are in pre-trial detention. The Dutch company of which the Russian national is a shareholder is also listed as a suspect.

The investigation relates to the suspected provision of prohibited IT services and the suspected export of high-tech goods “that can be linked to applications for the Russian defense industry” via a third country.

The Dutch company is said to be linked to a Russian company with clientele that includes “a sanctioned Russian bank, a high-tech software company, and a manufacturer of military helicopters”.

September 4, 2026 by Mark Handley

Sweden – extradition of Russian national to the US approved to face sanctions charges

It is being reported (here, behind a paywall), the Sweden’s Supreme Court has approved an request for a Russian national to be extradited to the United States to face charges arising from the alleged export of military components to Russia via Hong Kong.

September 4, 2026September 4, 2026 by Mark Handley

Luxembourg – investigation into alleged Russian sanctions breaches discontinued

Further to our earlier post regarding a Luxembourg investigation into possible EU sanctions breaches by the company Spacety Luxembourg SA, it is now being reported that the Luxembourg authorities have discontinued the investigation.

A government spokesperson is reported to have stated that the investigation was discontinued after several mutual legal assistance requests had been made, but it is unclear whether these requests were refused, and to which countries the requests were sent.

The company was placed into liquidation in October 2025.

September 1, 2026September 1, 2026 by Mark Handley

Netherlands – confiscation of proceeds from sanctions breaches reduced on appeal

Further to our earlier post regarding a 2024 conviction and confiscation, the Hague Court of Appeal has ruled on an appeal by the convicted defendants on the quantum of the confiscation.

The revenue from the criminal transactions was €1,924,579.20, with the first instance court allowing deductions of costs, to arrive at an initial confiscation order in the sum of €298,310. This was in line with the Dutch methodology of confiscating net profit rather than gross profit.

The defendant raised a number of arguments:

1) that there should be no confiscation;

2) that certain costs (transport, packaging, testing, etc) had been improperly not deducted from revenue;

3) that the value of confiscated goods should be credited in favour of the defendant; and

4) that the defendant did not have the financial means to satisfy the confiscation order.

All of these arguments were rejected by the Hague Court of Appeal. Despite this, the Court reduced the sum to be confiscated to €250,195. The Court provided no reasoning, or basis for, this reduction.

August 24, 2026August 24, 2026 by Mark Handley

Austria – two convicted for exporting sanctioned machinery to Russia

Further to our previous post, it is now being reported that the Austrian investigation into suspected exports of CNC machines has ended in two criminal convictions.

A 28 year old was the director and shareholder in the Vienna-based company involved. He received a 21 month sentence of which 19 months were suspended. He was released upon his conviction having already served more than two months in detention.

The second defendant was a 24-year old who dealt with the company’s accounts and was also a shareholder. She was given a 15-month suspended sentence.

Both had pleaded guilty to the charges.

The reporting makes no mention of a financial fine, or of any confiscation of the proceeds of crime.

July 20, 2026July 20, 2026 by Mark Handley

Netherlands – investment bank fined €8.5m for compliance failures, including sanctions

The Dutch DNB has issued an administrative fine to ABN Amro relating to compliance failings.

The fine was reduced from €10m to €8.5m as part of a settlement with the bank.

The sanctions element relates to a number of the customers included within the DNB’s investigated sample. As part of the assessment of these client files it was determined that there was an unaddressed risk that some of the clients were involved with dual-use goods with some indicators that the bank’s customers were using intermediaries in high-risk jurisdictions to evade or circumvent the EU’s Russian sanctions. The bank was also criticised for undue reliance on uncorroborated client declarations.

June 29, 2026June 29, 2026 by Mark Handley

Moldova – raids on company exporting dual-use goods to Russian military

Moldova’s Information and Security Service and Prosecutor’s Office for Combating Organized Crime and Special Cases, have conducted raids on the premises of Comelpro SRL.

The company is alleged to have exported technical equipment used in the propulsion systems of YAK-130 and SU-27 aircraft for the Russian military before sanctions were imposed, and then continued to do so by relabelling the exported products as “waste processing devices”, and declaring that the goods were being shipped to a front company in Russia.

The value of the exports is reported to be 21 million lei (approximately €1.03m).

June 12, 2026June 12, 2026 by Mark Handley

Belgium – three convicted of Russian sanctions breaches

Reuters is reporting that three individuals have today been convicted of Russian sanctions offences.

The offending involved the shipment of goods for the Russian defence sector via third countries including Hong Kong and Kazakhstan. The goods are described as “sanctioned goods, including rare earths, an explosive detector and a defence-related machine”.

The first defendant, named in the reporting as Victor Labin, was given an €80,000 fine and a five year prison sentence, with one year of that suspended.

The second defendant, reported to be Ruslan Labin, and tried in absentia was sentenced to six years in jail and an €8,000 fine.

The third defendant, named only as P.I., was given a three year sentence, suspended for five years, and an €8,000 fine.

June 10, 2026June 10, 2026 by Mark Handley

Poland – two charged with sanctioned exports of dual-use goods to Russia

Poland’s ABW (Agency for Internal Security) has issued a press release related to the charging of two individuals, Eduard K. and Krzysztof J., on suspicion of exporting dual use goods to Russia in breach of the EU’s sanctions.

The equipment was a CNC machine tool and a thermal chamber for metalworking. The equipment was purchased in Germany and transported to Poland before being shipped to Turkey for further export into Russia.

The goods were stopped from being exported and the two suspects have been detained since September last year.

The press release notes the availability of a sentence of not less than three years as well as confiscations.