France’s National Anti-Terrorism Prosecutor’s Office (PNAT) is reported to have confirmed to the Associated Press that it has charged five individuals on suspicion of fundraising for the designated terrorist group Hamas.
The arrests were done by the General Directorate for Internal Security which is leading the investigation said to have commenced in April of this year.
The authorities are seeking the continued pre-trial detention of the two of the suspects.
Further to our earlier post from 2024, it is now being reported that the Berlin Public Prosecutor’s Office is investigating possible breaches of the EU Russian sanctions relating to the now-closed ‘Russia House’ in Berlin which for many years had served as a cultural centre.
The Prosecutor’s Office is quoted as responding to query by stating that there are “ongoing investigations against unknown persons or tenants of the Russian House for violations of the Foreign Trade and Payments Act“.
It is being reported that the Regional Administrative Court of Lithuania has upheld a challenge to a fine of €418,677 imposed by the Financial Crime Investigation Service against the company Dage Capital for breaching the EU’s sanctions against Belarus.
The company sold luxury cars to entities in Poland and the UK for on-sale to Belarus.
The company was also found to have used accounts with the designated Alfa-Bank in Belarus.
It is being reported that Luxembourg’s Finance Ministry has tasked the public prosecutor to investigate suspected sanctions circumvention, and possible insider trading, by ex-managers of Gazprombank Luxembourg.
The bank and one of the ex-managers has denied wrongdoing.
The allegations arise out high profile reporting (behind a paywall, but also here) of a bond-trading scheme whereby cut-price Luxembourg bonds were swapped for full-priced bonds in Russia.
It was only in March that the blog passed the milestone of 700 posts, and now it is at 800. To mark the occasion we are publishing some graphs on the current state of enforcement across Europe.
Fines
The first graph shows (in blue columns) the annual values (in euros) of fines/confiscations/penalties/forfeitures for sanctions breaches across Europe from 2017 to 2026.
The green line is the number of fines in any given year valued at €1 million or more.
With nearly four months to go 2026 is at €115.3m and is on track to surpass both 2024 and 2019 in terms of total value (and 2019 had a single fine of £102m from the UK’s FCA).
What the graph also illustrates is that while 2018-2020 had a small number of very large fines, countries across Europe are now imposing a much higher number of significant fines than before.
Jail terms
The next graph is another way of showing the sea change in enforcement outcomes since 2022.
In the last three years over 175 years of jail time (not including suspended sentences) have been handed down. The adoption and implementation of the EU’s harmonization directive, is only going to reinforce and further drive this trend as more member states take on the power to impose a custodial sentence.
In an Administrative Sanction published by Luxembourg’s CSSF, a fine of €56,000 was imposed on Stonehage Fleming Luxembourg S.A.
Most of the notice relates to AML compliance failings, but included was a complaint as regards to the resolution of sanctions screening hits and a delay in implementing changes to lists for screening purposes:
“At the time of the on-site inspection, hundreds of name screening alerts had been treated with significant delays and 42 alerts remained unnoticed by the PFS. These delays constitute a breach of the obligations foreseen in Article 3(2) point (d) of the AML/CFT Law and in Article 33(1) of CSSF Regulation No 12-02, as the PFS was unable to identify “without delay” persons subject to restrictive measures in financial matters and therefore apply “without delay” potential restrictive measures in financial matters as the case may be“.
Further to an earlier post, it is being reported that police investigators from Czechia’s National Centre for Combating Organized Crime, who have been investigating alleged breaches of the asset freeze imposed on a designated person under the EU’s Russian sanctions, have now handed the case file to prosecutors for a final charging decision.
It is alleged that Dmytro Kalantyrskyi conducted multiple transactions in 2015 relating to frozen funds in the value of CZK 96 million (nearly €4m).
The UK’s Office of Financial Sanctions Implementation has issued a Penalty Notice against Citibank NA in the amount of £4,732,830.58.
This is OFSI’s second largest fine since it was launched.
The fine relates to 970 payments in breach of the UK’s Russian sanctions with a total value of £19,720,127.32 with most of the payments taking place in the months after February 2022.
OFSI have Citibank a 20% voluntary self-disclosure and cooperation credit (and not the permissible 30%). The bank had voluntarily self-reported many of the breaches and payments, but was unaware of £6.9m of the payments being breaches until OFSI started to raise questions.
OFSI also provided Citibank with a 20% discount based on agreeing a settlement, under OFSI’s fairly new settlement methodology.
These discounts, against a starting point where the maximum fine is 50% of the value of the breaches, resulted in the penalty amount. It is worth noting that the new Chancellor has announced plans to increase the maximum fine to 100% of the value of the transfer.
The breaches all related to failings and delay in screening customers, recipients and correspondent banks. While OFSI’s Notice expresses sympathy with the high volume of designations that took place in 2022, it was critical of Citibank’s level of preparedness in the run up to February 2022 and of the high volume of errors including changes in policy that made the prevention of payments more difficult. OFSI also was critical of the time taken for the bank to report that it was holding frozen assets.
It has been reported, here (behind a paywall), that TikTok Information Technologies UK Limited, has self-reported potential breaches of sanctions both to the UK’s Office of Financial Sanctions Implementation, and to Ireland’s Central Bank of Ireland, as well as to other unnamed regulators.
The information on the self-reporting comes from the most-recently filed company accounts, available from Companies House in England:
No other information is available on the sanctions regime, or regimes, involved, the nature of the potential breaches, or the progress in any regulatory investigations since April.
The Estonian case law website has made available a number of further judgments relating to convictions for sanctions offences:
Case 1. Judgment dated October 6, 2025
This case was the prosecution of Mati-Dmitri Terestal (see our earlier post). It was alleged that he, and another, had made economic resources and find available to a designated person who was the head of Yle1 (a Russian state-owned media outlet). It was alleged that Terestal continued to operate the media outlet after it had been closed, through a front entity and had continued to provide economic resources in the form of technical equipment, and other assets.
It was also alleged that by hiring staff for the company this was making economic resources available to Yle1, as was the creation of web domains.
The County Court had convicted Terestal in January 2025, and sentenced him to 2 years and 4 months, this was suspended for three and a half years. He was also fined €7882.92.
The District Court disagreed with the County Court on a number of issues (including whether hiring staff without more amounted to the making available of an economic resource, but upheld the conviction. The sentence was unchanged.
The decision includes a discussion of the characteristics of control for asset freeze purposes.
Case 2. Judgment dated January 21, 2026
The prosecution entered into an agreement with the defendants that was upheld by the court following guilty pleas by the defendants.
The defendants (a company and a director that company) had set out to create a fake network of transactions and sales in order to import bitumen from Russia in breach of the EU’s sanctions. The fake transactions involved front companies in a range of jurisdictions including Kazakhstan and Hong Kong. One member of staff (who was either not prosecuted or separately prosecuted) had the role of maintaining a watching brief on changes to the EU’s sanctions in order to develop changes to the methodology for masking the Russian imports.
The company, Keystone Shipping OÜ, was fined €250,000, ordered to pay costs of €61,928.18 and had bitumen valued at €179,200 confiscated.
Andrey Kolesnikov, the sole director of the company, was fined €32,110 and costs of €1,329.
Case 3. Judgment dated March 6, 2026
The case was an appeal to the District Court from a judgment of the County Court which had found two men guilty of attempting to export a BMW car to Russia in breach of the EU’s sanctions against the export of luxury goods. Vladimir Palamarchuk was fined €3000 and Igor Palamarchuk was fined €2000. In addition the car, valued at over €50,000, was confiscated as the proceeds of crime.
The appeal, which was largely based on whether the car exceeded the 50,000 threshold, was denied and the fines and confiscation upheld.
The judgment relied on the EU’s FAQs in relation to the process for determining the price of an exported good.
