United Kingdom – law firm fined £600 for breach of Russian sanctions licence conditions

The Solicitors Regulation Authority (the “SRA”) has fined Steptoe International LLP £600 and given the firm a “rebuke” for breaches of the UK’s Russian sanctions.

The breaches are reported to have related to two clients, and involved non-compliance with the conditions of relevant licences granted by OFSI, which is a criminal offence. It is unclear whether this was a general licence or a specific licence.

The firm self-reported the breaches to the SRA, which accepted that the breaches were the result of “inadvertent human error”.

The report makes no mention of any involvement by OFSI.

Portugal – court judgments reveal ongoing Russian sanctions investigations for breaches of bank deposit cap

In a first for this blog, we can report on sanctions enforcement activity in Portugal.

Three judgments from the Lisbon Court of Appeal reveal ongoing investigations into alleged breaches of the EU’s regulation 833/2014.

The judgments are each the dismissal of appeals by anonymised persons who have had bank accounts frozen pending the outcome of the the criminal investigations in question. In each case the investigation appears to be focussed on alleged breaches of regulation 5b of 833/2014 and the €100,000 deposit cap first introduced in February 2022.

The judgments are from:

a) 24 May 2023: in this case it is alleged that a Russian national (named only as YS) transferred over €1.8m for the purchase of real estate in Portugal in February and June 2022. The judgment mentions that YS had been a senior manager within Gazprombank.

b) 6 February 2025: in this case it is alleged that two Russian nationals (named only as AA and BB) transferred $6m from accounts in Russia and Austria in February and October 2022, and another €4.7m in February and March 2022 There is also an allegation that the transfers related to Tatyana Golikova, who is a designated person under the EU’s sanctions.

c) 11 March 2025: in this case it is alleged that two Russian nationals residing in Russia (named only as AA and BB) transferred several hundred thousand euros to bank accounts in Portugal.

    Sweden, Estonia and Lithuania: investigations opened into funding provided by Russian designated person

    Further to our earlier post regarding an investigation in Latvia into the activities of the designated Russian state entity “Pravfond”, it has now been reported that a number of other investigations are ongoing in relation to this entity’s activities:

    1) An investigation has been commenced in Sweden in relation to a school that had associations with Pravfond;

    2) In Estonia a multiple investigations (by the criminal authorities and the bar association) have been opened in relation to lawyers who accepted funds from Pravfond; and

    3) In Lithuania a criminal investigation has been opened (as well as one by the bar association) into lawyers who took funds from Pravfond.

      Netherlands – DNB issues instruction to trust office regarding sanctions compliance

      The Nederlandsche Bank (DNB) has issued a press release relating to Erez Corporate Service B.V.

      Erez was issued an “instruction” in June 2021 by the DNB in relation to the remediation of various compliance failings, including compliance with EU sanctions.

      Erez has sought to challenge, and then appeal, this instruction, but those efforts have not been successful which is why the DNB are now publishing the details of the instruction.

      Estonia – conviction and 2-year sentence for making economic resources available to a designated person

      Further to our earlier post, it has been reported that journalist Svetlana Burtseva has been convicted of breaches of the EU’s sanctions.

      The offence was committed by making “economic resources” available to a designated person. The designated person was the sanctioned media outlet Rossiya Segodnya.

      The “economic resources” were articles and photos written and taken by the journalist.

      Ms Burtseva was sentenced to 2 years in jail for this offence.

      Separately the same journalist was also convicted of treason and given a 4-year sentence for the treason offence.

      Latvia – 61 new criminal prosecutions for sanctions breaches commenced in 2025

      In a previous post from April we reported on the 2024 annual report for Latvia’s FIU.

      This included the statistic that 392 criminal proceedings had been commenced between 2022 and the end of 2024.

      In an interview recently published with Global Investigations Review (behind a paywall), the head of Latvia’s National Customs Board has stated that Latvia has now brought a total of 453 criminal prosecutions.

      This indicates that 61 new prosecutions have been brought so far in 2025.

      Latvia – sanctions investigation launched into activities of Russian state funder

      It is being reported that the Latvia State Security Service has launched an investigation into the activities of the sanctioned entity “Pravfond”.

      Pravfond is said to be a funding conduit by which the Russian state provides support for promoting Russia’s influence and interests abroad. It was designated under the EU’s Russian sanctioned in mid 2023.

      The allegation is that it has continued to operate and provide funding despite being subject to the asset freeze.

      United Kingdom – OFSI imposes £5,000 fine for refusing to respond to information request

      The UK’s OFSI has announced a £5,000 monetary penalty imposed on Svarog Shipping & Trading Company Limited.

      The fine was for failing to respond to an information request from OFSI in breach of regulation 74(1)(a) of the UK’s Russian sanctions regulation.

      The Penalty Notice states that the request for information was made in the context of a wider “large and complex investigation into suspected breaches” of the UK’s sanctions in relation to Sovcomflot. That investigation is, presumably, ongoing.

      Latvia – updated sanctions enforcement statistics

      The Financial Intelligence Unit of Latvia has published its Financial Integrity Newsletter for its activity during 2024.

      This includes a range of sanctions enforcement-related statistics:

      • 451 suspicious activity reports in relation to suspected sanctions breaches;
      • attempted cash exports to Russia of €18.9 million stopped;
      • more than 8,500 shipments across Latvia’s border with Russia stopped, of which 89% were exports and 11% were imports; and
      • 392 criminal proceedings started between 2022 and the end of 2024.

      The Newsletter does not provide figures on the outcomes (to date) of the 392 criminal proceedings.

      Estonia – details of eleven Russian sanctions convictions

      Further to the earlier post about Estonia having obtained 8 criminal convictions during 2024, we can publish details of the criminal convictions for breaches of the EU’s Russian sanctions that have been published on Estonia’s searchable gazette of published judgments.

      As well as one conviction obtained in 2022, below we are publishing summaries of seven of the convictions from 2024 and three from 2025 (not including the conviction made public on 16 April 2025) as well as machine translations of the respective judgments.

      The sentences range from fairly small monetary fines up to custodial sentences of 5 years in jail.

      1. Judgment of 10 October 2022 – Petr Rafalovich (a Belarus national) was convicted and given a two month sentence following which he was to be deported to Belarus and given a five-year ban from re-entering Estonia. He was also ordered to pay a penalty and costs of €1,250.40.

      The offence was the attempt to export a 3D printer and an electromagnetic positioner. Mr Rafalovich was carrying false papers indicating the goods were destined for an Armenian company, as well as other papers indicating the true recipient to be a Russian company.

      2. Judgment of 5 February 2024 – Victor Manilo was convicted and ordered to pay €2,680 as a fine.

      The offence was the attempted export of €14,000 in physical currency to Russia.

      3. Judgment of 14 February 2024 – Galina Sergejenkova was convicted and ordered to pay €3,960, such payment suspended for a probationary period of 18 months. A separate payment of costs and a penalty of €1,434.96 were to be paid straightaway.

      The offences were two attempts to transport physical currency (of €900 and €1,000 respectively).

      4. Judgment of 27 February 2024 – Evgeniy Kozlovtsev was convicted and given an eight month sentence suspended for a probationary period of 18 months. He was also ordered to pay a penalty and costs of €1,430.

      The offence was the attempted export to Russia of two bottles of wine greater than the €300 luxury threshold. It was the man’s second attempt at such exports.

      5. Judgment of 8 March 2024 – Aleksei Bond was convicted and given a five month prison sentence suspended for a probationary period of 18 months. He was also ordered to pay a penalty and costs of €1,555.

      The offence was the attempted export of a luxury watch valued at €13,900 to Russia.

      6. Judgment of 27 March 2024 – Lev Pylkin was convicted and ordered to pay a penalty of €1,190, as well as confiscation of the cash he attempted to export to Russia.

      The offence was the attempted export of €2,560 in physical currency across the border to Russia. He had previously attempted to export cash at which time the details of the offence had been explained. The judgment is the dismissal of an appeal against the conviction and sentence.

      7. Judgment of 17 October 2024 – Ruslan Sibilev was convicted and ordered to pay a fine of €79,557.50 as well as confiscation of a large number of rifle scopes, binoculars and other equipment.

      The offences were committed through the acquisition of a range of sanctioned goods from a Portuguese company and an Austrian company, with Sibilev acting to coordinate further transport for the export of the goods to Russia. The orders were placed between May 2022 and April 2023. The total value of the goods ordered was nearly €1 million.

      8. Judgment of 16 December 2024 – Oleg Osipov was convicted and sentenced to 8 months in prison suspended for a probationary period of 18 months. He was also ordered to pay €13,230, including 100% of the fee earned as part of the sanctioned transactions.

      The offences were committed through Osipov providing a brokering service for the export of luxury goods to buyers in Russia between May and July 2023. The goods included electrical goods, phones, alcohol, navigation systems and various automotive parts. Osipov contracted with others to deliver the goods and took a brokering fee for arranging the transactions.

      9. Judgment of 14 February 2025 – Demyan Belyakov was convicted and sentenced to 5 years in jail and ordered to pay €8,231 in costs and other penalties. In addition a large volume of goods were confiscated.

      The offences were committed through the actual and attempted export to Russia of hundreds of silencers and firearm flash suppressors between February and June 2024.

      10. Judgment of 20 February 2025 – Andrei Klychkov was convicted and sentenced to serve two months in prison plus a further period of 2 years and 10 months suspended for a probationary period of 4 years. €5,000 was also confiscated and he was ordered to pay costs of €2,581.

      The offences were committed by the attempted export of parts for firearms, to Russia.

      11. Judgment of 21 March 2025 – Aleksandr Ivantsov was convicted and sentenced to 4 years, 11 months and 27 days (after deducting 3 days of pre-trial detention) suspended for a probationary period of 5 years and other conditions including a requirement for prior permission to be away from his house for more than 15 days, and permission to leave Estonia. He was also ordered to pay €2,215 and had 70,550 rubles, and other goods, confiscated.

      The offence was committed by the attempted export of six pairs of night-vision binoculars.

      This case is related to that above for Ruslan Sibilev with Mr Ivantsov being one of the people used to try and physically carry the goods across the border into Russia.

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      The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

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