Financial Sanctions – European Sanctions Enforcement

April 16, 2025 by Mark Handley

Estonia – criminal sanctions conviction for accepting funds from designated person

The Estonian authorities have secured a guilty plea as part of a plea deal by an individual who accepted funds from a designated person.

The accused, Tatjana Sokolova, received payments into Russian bank accounts from “The Foundation for the Support and Protection of the Rights of Compatriots Living Abroad” – a designated person under the EU’s sanctions.

The funds were withdrawn and carried into Estonia in person. The money was to be used to fund the defence of another individual who was being prosecuted for crimes against the Estonian state.

The sentence is for 360 hours of community service, with the 12-month unserved part of a 16-month prison sentence to be suspended pending completion of the community service.

Cash of €10,000 found when Sokolova was arrested has been confiscated and she was ordered to pay €1389 in court costs.

April 14, 2025April 14, 2025 by Mark Handley

United Kingdom – sentencing for first Russian sanctions convictions

Further to last week’s post, sentencing has now been completed against Dmitrii Ovsiannikov and Alexei Owsjanikow, who were both convicted of breaches of the UK’s sanctions regime.

As per a press release from the Crown Prosecution Service, Ovsiannikov was convicted of 8 counts of breaking the asset freeze imposed upon him as a designated person, and has been sentenced to 40 months in prison for each count with each sentence to be served concurrently. He was also convicted of two charges of money laundering.

The charges relate to the purchase of a car, the payment of private school fees, deposits into bank accounts and insurance.

Alexei Owsjanikow was convicted of 2 of the charges against him, relating to the payment of school fees on behalf of his brother-in-law, and was given a suspended 15 month prison sentence and made subject of a curfew order.

April 10, 2025April 10, 2025 by Mark Handley

United Kingdom – first criminal convictions under the UK’s Russian sanctions

It is being reported that the jury in the criminal prosecution of designated person Dmitrii Ovsiannikov, his wife Ekaterina Ovsiannikova, and his brother in law Alexei Owsjanikow have returned two guilty verdicts and one acquittal.

See our earlier posts on the progress of this case here and here.

These are the first criminal convictions obtained by the UK authorities under the UK’s Russian sanctions regime, and the first criminal conviction under any sanctions regime since 2017. It is also a rare example of the prosecution of a designated person.

Ekaterina Ovsiannikova was acquitted on four counts of circumventing sanctions arising from payments to her husband of £76,000 in 2023.

Alexei Owsjanikow was acquitted of several counts relating to access to a car, arranging car insurance and use of a bank account. He was, however, convicted of two counts of circumventing sanctions relating to the payment of £41,027 in private school fees.

Dmitrii Ovsiannikov was convicted of six of the seven counts he was charged with, all relating to breaches of the asset freeze imposed upon him by reason of his status as a designated person.

Sentencing will take place in due course, and it is to be hoped that the judge’s Sentencing Remarks are made public.

April 8, 2025April 8, 2025 by Mark Handley

Switzerland – Attorney General’s Office provides details on two ongoing criminal sanctions cases

The Annual Report of the Swiss Attorney General’s Office (OAG) contains details on two ongoing criminal sanctions cases which it has taken over from SECO. Both cases arise under Switzerland’s Russian sanctions.

In one the OAG state that they have conducted search at eight residential properties in the cantons of Lucerne, Zug and Nidwalden. The investigation is said to relate to both an asset freeze imposed on a designated person and suspected breaches of the Swiss Embargo Act.

Assets which are the subject of “super-provisional freezing” as part of this investigation are said to total CHF 1.3 billion (or c. €1.39 billion).

Less information is given on the second investigation other than that it is “in connection with suspected sanctions violations by a Swiss company via subsidiaries abroad”.

April 2, 2025April 2, 2025 by Mark Handley

Netherlands – person arrested on suspicion of terrorist sanctions breaches

The Dutch FIOD, has issued a press release regarding its arrest of a 32-year old man suspected of violating the Dutch Sanctiewet 1977 through the suspected transfer of bitcoins to sanctioned terrorist organisations between 2020 and 2022.

The investigation was commenced as a result of a suspicious activity report made by a crypto exchange to the Dutch FIU.

April 2, 2025April 2, 2025 by Mark Handley

Switzerland – updated enforcement statistics with 9 new convictions since September 2024

Switzerland’s SECO has given an update on its ongoing enforcement actions.

It has received 600 reports of suspected sanctions breaches, and it has opened 68 penalty proceedings, of which 24 have resulted in final fines.

As per our earlier post, as of September 2024 the figure was at 15 final convictions, meaning that another 9 have been added since then.

No figure has been given for the penalties imposed.

April 2, 2025 by Mark Handley

Switzerland – update on ongoing criminal sanctions proceeding

Further to our earlier post from August 2024, the Swiss authorities have provided an update on one of their ongoing criminal sanctions investigations.

The investigation relates to people linked to Suleiman Kerimov, a designated person under Swiss sanctions.

As of August 2024 it was an investigation into four people, it is now being reported that the Swiss authorities have confirmed that the case has moved to an ongoing criminal proceeding, and that there are five individual defendants.

April 2, 2025 by Mark Handley

France – TV regulator orders satellite provider to stop broadcasting sanctioned Russian channels

The French media regulator , Arcom, has issued an order to Eutelsat ordering it to cease the broadcasting of two channels owned or controlled by JSC National Media Group which is a designated person under the EU’s Russian sanctions.

The channels are STS and Kanal 5.

Earlier reports had suggested that Arcom might impose a fine on Eutelsat, but no fine was imposed.

April 2, 2025 by Mark Handley

Germany – four charged under ISIS sanctions

It is being reported that the German Prosecutor’s Office has charged four Russian nationals with making funds available to ISIS in breach of the EU’s sanctions.

One individual was arrested in January of this year and three others in July of 2024.

They are accused of raising €174,000 for ISIS and then sending that to ISIS via various channels.

March 21, 2025March 21, 2025 by Mark Handley

United Kingdom – OFSI fines Moscow subsidiary of UK law firm £465,000

The UK’s OFSI has published a penalty notice imposing a £465,000 fine on Herbert Smith Freehills CIS LLP (“HSF Moscow”) – a UK LLP which operated as the Moscow office of the law firm Herbert Smith Freehills (“HSF”)

The fine was reduced by half due to prompt self reporting by HSF (all the breaches had been reported by 15 July 2022) and further co-operation in the form of the conduct of an internal investigation.

The breaches of the UK’s sanctions were all done by HSF Moscow between 25 and 31 May 2022. The breaches arose from six payments made to designated persons with a total value of £3,932,392.10. The six breaches were:

a payment into a bank account held at Sberbank (a designated bank) to clear an overdraft;
Payment of three invoices valued at £3,903.76 for insurance issued by Sovcombank Life, a wholly-owned subsidiary of Sovcombank (a designated bank);
Payment of £13,216.32 as a redundancy payment to an employee’s bank account held at Sberbank; and
Payment of £3,915,232.31 into an account held by Alfa-Bank (a designated bank), although the transfer was swiftly reversed.

This case emphasizes above all the approach that OFSI takes in relation to accounts held at designated banks. In the view of OFSI payments into such accounts, albeit accounts held by non-designated persons, will amount to making funds available to a designated person.

In relation to the payment to a subsidiary of a designated person, OFSI also emphasizes the importance of appropriate due diligence to understand possible issues of ownership and control.