Dual-Use Goods – European Sanctions Enforcement

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.

June 1, 2026June 1, 2026 by Mark Handley

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.

March 18, 2026March 18, 2026 by Mark Handley

Latvia – 11 year jail sentence for exporting Starlink kits to the Russian military

The Latvia Prosecutor’s office has secured a conviction and 11-year jail term against an Azerbaijani national.

Three other defendants (including two Latvian nationals) are to be tried separately.

The man was convicted for his role in exporting dozens of Starlink Mini Kits to the Russian military, as well as “other goods used for military activities, including weapons parts, cartridge shells, bullets, ballistic weather meters, in total worth about 200, 000 euros”.

As well as sanctions offences the man was convicted of being part of an organised group to assist a foreign state in undermining the territorial integrity and independence of a democratic state.

In addition to the 11-year jail term, upon release he will be expelled from Latvia and be subject to a 5-year ban on re-entry.

This is the longest known sentence for breach of the EU’s Russian sanctions.

March 16, 2026March 16, 2026 by Mark Handley

Spain – prosecution for military exports to Russia

It is being reported that the Spanish authorities are bringing a criminal prosecution for suspected exports of military aircraft engines to Russia in breach of the EU’s sanctions.

One individual, Olga V, has been in custody since her arrest in 2023. Another individual, Kostiantyn Antonovich Kucher, former Ukrainian Deputy Minister of Industrial Policy, is in detention in Azerbaijan pending extradition proceedings to bring him to Spain.

It is alleged that the two, and a network of companies (including Aero Design Systems and Global Force Technology), sought to export aircraft engines to Russia including to the United Aircraft Corporation.

The investigation has included the seizure of three engines by German customs.

February 26, 2026February 26, 2026 by Mark Handley

Belgium – trial of three individuals for dual-use exports to Russia

Further to our post from last week regarding the prosecution of a Russian national in Belgium, for Russian sanctions breaches, it is now being reported that the prosecution is targeting three individuals.

The second suspect is the son of Viktor Labin (the first defendant). He is said to be currently living in Russia and the subject of an international arrest warrant.

The third suspect is currently out in bail.

The dual-use goods said to have been exported to Russia include iron, alumina, yttrium oxide, and explosive propagation detectors.