Export Controls – European Sanctions Enforcement

April 10, 2025April 10, 2025 by Mark Handley

United Kingdom – export control compound penalties issued totalling £3.7m

Yesterday the UK’s HMRC issued a Notice to Exporters publishing three recent compound penalties issued to exporters.

In line with HMRC policy when agreeing to a compound penalty resolution, the information provided on the offending, the offender, and the co-operation provided is limited, although in this instance it is specified that the penalties do not relate to sanctions breaches. The detail available states:

The settlements relate to unlicensed exports of military-listed goods and related activity prohibited by The Export Control Order 2008 and contrary to The Customs and Excise Management Act 1979. These do not relate to sanctions offences.

The 3 settlements agreed with UK companies were:

January 2025 – £10,900.00 was paid for export license breaches in relation to the export of military goods controlled by The Export Control Order 2008
February 2025 – £431,232.20 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008
February 2025 – £3,231,762.40 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008“.

March 5, 2025March 17, 2025 by Mark Handley

UK – compound penalty of £374,326.07 for unlicensed exports of dual-use goods

The UK’s HM Revenue and Customs has published a compound penalty of £374,326.07 against an unnamed UK company for “unlicensed exports of dual-use goods and failure to declare a licence to customs”.

No further details were provided as to the nature of the conduct or the basis for offering a compound penalty rather than a prosecution.

February 28, 2025February 28, 2025 by Mark Handley

United Kingdom – HMRC has opened 65 trade sanctions investigations since 2022

In a letter written from the UK’s HMRC (the body with primary responsibility for the criminal enforcement of trade sanctions) to Parliament’s Treasury Select Committee, HMRC has provided significant information on its recent enforcement efforts.

Year	Number of investigations opened
2021	0
2022	14 (all relating to Russian sanctions)
2023	22 (20 relating to Russian sanctions)
2024	29 (27 relating to Russian sanctions)

Of those 65 investigations, HMRC has confirmed that 30 remain live of which 27 relate to Russian sanctions.

The letter tabulates the six fines imposed to date for breaches of the Russian sanctions, and in relation to the largest single fine of £1,000,000 imposed in August 2023 (see our earlier post), the letter notes that this fine relates to “brokering and technical assistance” and not to an actual export.

HMRC’s letter also states that a previously published compound penalty of £1,000 from September 2023 (see our earlier post) was actually for a breach of the UK’s Iran sanctions despite being described at the time as “relating to the attempted export of Dual Use goods”.

HMRC’s letter also states that in October 2024 it referred a case for possible prosecution to the Crown Prosecution Service.

February 17, 2025February 17, 2025 by Mark Handley

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.

December 17, 2024April 3, 2025 by Mark Handley

United Kingdom – company convicted of export control violations

His Majesty’s Revenue and Customs (HMRC) has announced the conviction of the company EDM Limited on three counts of exporting controlled military goods without the appropriate licence.

The goods in question were military flight simulators valued at £38,967.68.

The company was fined £89,359.80, including costs, but HMRC’s Notice does not mention whether a confiscation order was also made.

EDM Limited had been offered a civil compound penalty to resolve the matter but had not accepted the offer in time and so the case went to trial.

November 4, 2024November 4, 2024 by Mark Handley

United Kingdom – HMRC compound penalties for Russian sanctions and export control violations totaling £1.9m

The UK’s HMRC has issued several “Notices to Exporters” with updates as to recent enforcement activity.

In one Notice, HMRC states that is has agreed three compound penalties with different entities:

“August 2024 – £402,417.75 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008
August 2024 – £37,743.34 was paid relating to the unlicensed exports of dual-use goods controlled by Retained Regulation 428/2009
September 2024 – £1,480,785.44 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008″

As ever with such penalties the nature of the offending is not given, the identity of the offender is not given, and no indication is given as to whether or not the fine includes a confiscation element for the proceeds of the crimes.

In a second Notice, HMRC describes the compound penalty:

“August 2024 – £58,426.45 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019”.

Again, no other details or information is provided, although HMRC notes that this is its 6th compound penalty in relation to Russian sanctions totaling £1,363,129.

October 18, 2024 by Mark Handley

Norway – 37 ongoing Russian sanctions investigations

It is being reported that Norway’s Politiets Sikkerhetstjeneste (Norwegian Customs), has 37 ongoing investigations in relation to alleged breaches of Norway’s Russian sanctions. Many of these are said to involve attempts to evade detection by exporting to Russia via third countries, but some are described as relating to imports into Norway.

It is also being reported that there is a further investigation under Norway’s Export Control Act.

October 15, 2024 by Mark Handley

Finland – three Russian nationals under investigation for dual-use exports

Further to our earlier post from May when three Russian national university students were arrested in Finland, an update on the case has now been reported.

The investigation of all three individuals continues, with two having been released from custody over the summer and the third recently released.

The conditions of bail include a travel ban, and it is said that the three are being investigated in relation to the “gross regulatory crime” of exporting dual use goods from Finland to Russia in breach of EU sanctions.

It is unclear whether this case is related to Tampere University recently reporting itself to the Finnish police.

October 10, 2024October 10, 2024 by Mark Handley

Finland – university calls in police to investigate suspected breach of sanctions

It is being reported that the University of Tampere in Finland has asked the police to investigate a suspected breach of sanctions “at the institution”.

The suspicions relates to potential breach of sanctions as well as export controls on dual-use goods. The particular sanctions regime involved is not specified in the material that is public.

Little other information is available including whether the suspicions relate to staff or students.

September 11, 2024 by Mark Handley

UK – HMRC fines two companies for export control breaches

The UK’s primary export controls enforcement body, HMRC, has today issued a Notice to Exporters giving some details on two compound settlements reached with two UK companies.

The first was reached in April 2024 and the unnamed company agreed to pay £258,000 in relation to the “unlicensed transfer of dual-use goods controlled by Retained Regulation 428/2009”.

The second was reached in June 2024 and the unnamed company agreed to pay £90,853.20 in relation to the “the unlicensed exports of military goods controlled by The Export Control Order 2008”.

No other information has been made available.