Export Controls – European Sanctions Enforcement

September 15, 2026September 15, 2026 by Mark Handley

Finland – investigation into suspected exports of nearly €6m in sanctioned goods to Russia

Finland’s Customs has issued a press release relating to the latter stages of an investigation into suspected exports to Russia of nearly €6m in “hydraulic pumps and motors as well as various valves” in breach of the EU’s sanctions.

The exports were declared as destined for Kazakhstan and Türkiye, but are alleged to have been exported to Russia.

Two individuals are the suspects with the offences treated as aggravated offences. One of the suspects is also said to be the subject of four other criminal matters pending in the courts.

The press release note that the case will be forwarded to prosecutors by the end of the year.

September 9, 2026September 9, 2026 by Mark Handley

UK – HMRC issues £7.4m penalty for supply of goods to Russia

The UK’s HM Revenue and Customs has issued its largest sanctions-related Compound Penalty to date.

The company, Illumina Cambridge Limited, was fined £7,438,840.13 for breaches of the UK’s Russian sanctions.

The published Notice gives limited information on the breaches:

“Between July 2022 and January 2023 Illumina breached regulation 25(1) through their involvement in the supply of sanctioned goods from one overseas company within their corporate group to another overseas company within their corporate group for export to Russia and other destinations“.

Regulation 25(1) prohibits the direct or indirect making available of “restricted goods” or “restricted technology” either for use in Russia, or to a person connected with Russia.

Illumina Cambridge Limited voluntarily disclosed the conduct to HNRC and cooperated with the investigation.

As noted by HMRC “sanctions breaches can occur when UK businesses are involved in supply chains that result in sanctioned goods being supplied indirectly to Russia (or other countries subject to trade sanctions), even when no goods have been exported from the UK“.

This is the third large fine/forfeiture handed out by UK authorities in the last few weeks following the £4.7m fine from OFSI (2 September) and the $5.2m forfeiture from the National Crime Agency (27 August).

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 3, 2026September 3, 2026 by Mark Handley

Latvia – Customs confiscates €15m in sanctioned goods

A broadcast news story has provided data on the enforcement activity of Latvia’s Customs.

The story reports that:

roughly twice a week a shipment of sanctioned goods to Russia is stopped;
30 cargoes of military goods have been stopped; and
Customs have confiscated €15m in sanctioned goods through its work at inspections at checkpoints, of which roughly €3m has so far been sold.

The new story does not state over what period the confiscations took place.

August 3, 2026August 3, 2026 by Mark Handley

United Kingdom – two fines for military export control breaches

On 27 July, the UK’s HM Revenue and Customs issued a “Notice to Exporters” relating to two companies fined £216,530.30 and £20,889.15 respectively.

The companies were not named.

The conduct was not described in any detail and only said to “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”.

The details of why and how these companies were able to secure a resolution via a compound penalty were also not provided, although the Notice says in general terms:

“Compound settlements may be offered where an exporter has:

voluntarily told HMRC about sanctions or export control breaches, and
committed a breach that was inadvertent or due to weaknesses in internal controls”.

July 30, 2026July 30, 2026 by Mark Handley

United Kingdom – £6.4m fine for strategic export control failures

Further to our earlier post reporting on the UK’s investigation into Airbus, HMRC has today issued a Notice to Exporters that Airbus Operations Limited (AOL) has entered into a compound settlement with HMRC under which it will pay a fine of £6,409,388 for offences under The Export Control Order 2008.

This is the largest fine imposed by HMRC under the compound settlement regime, and is another example of the new practice of sometimes naming companies that enter into such settlements.

The offences do not relate to sanctions but to the UK’s strategic export controls regime.

The breaches took place “over a sustained period” before November 2022 and were self-reported by AOL which cooperated with the investigation and has implemented remediation.

The breaches are described in only general terms as follows:

Article 29(2)(a-g) on multiple occasions for failing to keep accurate records of transfers of controlled technology as per the conditions of three of their Open General Export Licences (OGELs)
Article 29(3) on multiple occasions for failing to keep registers in relation to their OGELs
Article 29(2)(i) on multiple occasions for failing to keep accurate records contrary to the conditions of one of their OGELs
a Standard Individual Export Licence (SIEL) on one occasion, relating to a failure of licence conditions

July 20, 2026July 20, 2026 by Mark Handley

United Kingdom – sanctions enforcement statistics for HMRC in 2025/26

The UK’s HMRC has released enforcement statistics for 2025 and the first part of 2026 in a “Technical Note”:

22 criminal investigations with three charges and two (at the time of the release of the Note) pending trial;
58 seizures of sanctioned goods
1 compound penalty of £1,160,725.67 (see our previous post);
29 self-disclosures, with these being resolved as follows:
- 18 warning letters;
- 7 no further action letters;
- 1 compound penalty;
- 3 cases remain unresolved.

By way of cooperation with the Office of Trade Sanctions Implementation, there were 44 referrals to HMRC in 2025/2026, with 10 resulting in no further action, 13 relating to already-ongoing investigations; and 21 still under review.

June 29, 2026June 29, 2026 by Mark Handley

UK – compound penalty of £569,157 imposed on named energy company

The UK’s HM Revenue and Customs has announced the imposition of a compound penalty of £569,157 on Petrofac Facilities Management Limited.

This is the first time, in a long time, that HMRC has named the recipient of a compound penalty.

The breaches took place in 2022 and 2023 with the company supplying prohibited goods to individuals connected with Russia and also providing technical assistance in relation to those goods.

The company subsequently self-reported and cooperated with the investigation.

The change in naming policy is addressed:

“Naming those involved brings us into line with other enforcement partners whilst sending a clear message on the consequences of breaching sanctions rules.”

The Notice further states that “Where appropriate, HMRC will now include naming as a condition when offering a compound settlement for strategic export and sanctions offences“. It appears that naming will now become more common if not done universally.

The Notice also gives helpful guidance on when HMRC will consider a compound penalty rather than prosecution, noting that a penalty will only be pursued where HMRC considers it has enough evidence to prosecute, and other considerations, including:

the seriousness of the alleged offence;
whether fraudulent intent can be proven;
the extent of the efforts to perpetrate the alleged offence;
the type and value of any goods involved;
the offender’s previous history;
the extent to which the offender has co-operated with any investigation; and
the level of financial penalties known to have been imposed by courts for similar offences.

June 12, 2026June 12, 2026 by Mark Handley

UK – two convicted for tens of millions in prohibited arms sales

HM Revenue and Customs has issued a press release relating to yesterday’s conviction of David Greenhalgh and Christos Farmakis on multiple counts (nine and ten respectively) of unlawful exports of military hardware in breach of UK sanctions and arms embargos under the Export Control Order 2008.

Mr Farmakis was tried in absentia with HMRC stating that he is thought to currently be in Greece and that HMRC is “working with international partners to bring him to the UK to face justice”.

Sentencing is due to take place in July, with the judge reported as saying that Mr Greenhalgh should expect a lengthy custodial sentence.

The unlicensed sales and exports were to Sudan, South Sudan and Libya between 2009 and 2016 and were largely of ex-Soviet equipment including “ex-Soviet jets, surface-to-air missile systems, anti-tank missiles, thousands of assault rifles and other controlled goods”.

The transactions were conducted through Mr Greenhalgh’s companies and involved circuitous transport routes as well as faked end-user certificates.