Financial Sanctions – European Sanctions Enforcement

May 22, 2026May 22, 2026 by Mark Handley

Netherlands – two arrested on suspicion breaching the sanctions on a designated person

The Dutch FIOD has issued a press release relating to the arrest of 59 and 37 year-old men from Amsterdam and the Hague respectively. Three business premises were also raised and searched.

The investigation relates to a web-hosting company founded in 2022 and designated by the EU in May 2025 for its role in the facilitation of “destabilizing activities directed against the European Union, including interference, cyberattacks and the spread of disinformation”. Following the designation the 57-year old set up a new company in the Netherlands which is alleged to have acted as a front for the continuing operations of the sanctioned entity.

A second Dutch company, of which the 39-year old was the sole shareholder and director is alleged to have played a facilitating role in providing interet connectivity.

May 19, 2026May 19, 2026 by Mark Handley

UK – OFSI fines bank £165,000 for processing transfers to an entity wholly-owned by designated person

The UK’s Office of Financial Sanctions Implementation has issued a Penalty Notice against the London branch of Deutsche Bank AG fining it £165,000.

The fine related to two payments made in June 2022 and July 2022 that had been voluntarily reported to OFSI in September 2022. The “pace” of resolving this matter is in keeping with previous cases from OFSI.

The first payment leading to the fine was of £356,429.27 processed on 29 June 2022 in favour of a company called Okko LLC. Earlier that same day the UK had designated the 100% shareholder of Okko, JSC New Opportunities.

The second payment of £279,189.48 was made a month later.

OFSO took the view (particularly in light of the second payment) that even though there had been a limited window to stop the first payment, nonetheless there was such a window. The screening methods used by Deutsche Bank failed to identify that a newly-designated entity wholly-owned the intended transferee. This failing continued for the next month and was not purely a function of the short window for the first payment.

OFSI also took the view that the breaches could only be seen as such after the UK adopted a strict liability rule for the civil enforcement of sanctions breaches on 15 June 2022. An additional payment made before this date, was not considered a “breach” for this reason.

The notice was resolved under OFSI’s new settlement regime, and involved a 45% discount on what would otherwise have been a £300,000 fine based on the self-disclosure and Deutsche Bank agreeing to settle.

May 18, 2026May 18, 2026 by Mark Handley

Switzerland – investigation into financial sanctions circumvention

As part of the Annual Report for 2025, Switzerland’s Federal Police Agency (Fedpol) has included information on an investigation into Russian funds held by an unidentified sanctioned Russian oligarch (the report uses the name “Aleksandr*” but this is not the person’s real name.

The report makes mention of a number of suspicious activity reports filed by Swiss private banks, and cooperation with an unnamed foreign country led to a significant investigation:

“The investigation revealed that Oleg and Dimitri owned assets in several cantons. The competent foreign criminal prosecution authority submitted a request for mutual legal assistance to the Federal Office of Justice with the aim of searching the premises and seizing the assets of Oleg and Dimitri, in particular bank accounts and real estate. A cantonal public prosecutor’s office was responsible for processing the request for mutual legal assistance. fedpol coordinated the case in Switzerland and abroad. By the end of 2025, the operation was underway, with more than 50 Swiss investigators and prosecutors from several cantons involved.

The seizures would first take place in Switzerland, with further actions in other European countries scheduled to follow. To this day, this remains one of the largest cases involving money laundering for the purpose of evading sanctions“.

The report does not discuss the outcomes of the investigation so far.

May 8, 2026May 8, 2026 by Mark Handley

Poland – publication of sanctions enforcement statistics including 138 fines imposed

The government of Poland has issued a press release detailing its efforts to date on the enforcement of the EU’s sanctions against Russia and Belarus.

My thanks to Dr Marcin Lukowski for drawing this release to the blog’s attention.

To date Poland has:

imposed fines of PLN 74.4m (c. €18m) across 138 separate fining decisions; and
in the first quarter of 2026 there are:
- 191 pending cases;
- 122 cases where an individual has been identified as a suspect (“charged” in Polish terminology);
- 13 indictments filed; and
- 10 final judgments.

The government also states that it has frozen €546.2m in assets, and that nearly 56% of all EU customs alerts originate from Poland.

As per our earlier post from September 2025 – at that stage Poland had imposed 42 fines for a total of PLN 26.6m or €6.2m, meaning the number of fines, and the value of fines imposed, has nearly tripled since September last year.

April 24, 2026April 24, 2026 by Mark Handley

Cyprus – investigation into possible Russian sanctions breaches by subsidiaries of Indian group

Tucked away in a Guardian article otherwise about allegations of breaches of the UK’s sanctions, it is being reported that the Cypriot Ministry of Finance has confirmed that it is investigating whether Cypriot subsidiaries of the Essar Group entered into transactions with Russia’s VTB Bank that breached, or circumvented, the EU’s sanctions.

The allegations relate to the movement of debt obligations owed by the Essar Group to VTB Bank from Cyprus to Mauritius in 2022.

April 20, 2026April 20, 2026 by Mark Handley

United Kingdom – former designated person charged with breaching his asset freeze under Russian sanctions

The UK’s National Crime Agency has published a press release confirming that it has charged John Michael Ormerod with two counts of breaches the UK’s Russian sanctions as well as a money laundering offence.

Ormerod was designated by the UK on 20 May 2025, and the charges relate to his efforts to transfer £200,000 on the same day in breach of the asset freeze imposed upon him.

Ormerod’s UK listing had been lifted on 2 March 2026.

April 13, 2026April 14, 2026 by Mark Handley

France – cement maker Lafarge and eight executives convicted of sanctions and terrorist financing breaches

Further to our earlier posts, a court in Paris had today handed down judgment in the long-running Lafarge prosecution.

The company has been convicted of breaches of the EU’s Syrian sanctions as well as terrorist financing and has been fined €1.125m as well as a separate fine of €4.57m for breach of sanctions.

Of the executives also being prosecuted:

– Bruno Pescheux (former director of the Syrian cement factory) received a 5-year jail term and was fined €225,000;

– Bruno Lafont (former Lafarge CEO) was sentenced to 6 years in jail and fined €225,000;

– Christian Herrault (former deputy Managing Director) was sentenced to five years in jail and fined €225,000;

– Frederic Jolibois (successor to Pescheux) was sentenced to three years in jail, two of which were suspended, and fined €80,000;

– Jacob Waerness was sentenced to 18 months in jail and fined €20,000 and a ban from entering France;

– Ahmad Al Jaloudi was sentenced to 2 years in jail and fined €20,000 and a ban from entering France;

– Amro Taleb, a Syrian intermediary, was sentenced to 3 years in jail and fined and fined €60,000 and a ban from entering France;

– Firas Tlass, tried in absentia, was convicted and sentenced to seven years in jail with a €225,000 fine and a ban from entering France.

It appears that a decision on the confiscation of the proceeds of crime in this case is awaited. The prosecution was seeking confiscation of €30m.

Some of the individual defendants have already indicated their intention to appeal.

April 6, 2026April 6, 2026 by Mark Handley

Bulgaria – extradition to face US sanctions charges

Further to our earlier post, it is now being reported that the Bulgarian authorities have extradited Russian national Oleg Olshansky to face charges of breaching the US’s Russian sanctions and money laundering.

Mr Olshansky had appealed an earlier decision approving his extradition.

Mr Olshansky and another Russian national extradited from Bulgaria, Mr Sergey Ivin have now been charged by the US authorities.

April 1, 2026April 1, 2026 by Mark Handley

United Kingdom – Irish subsidiary of Apple fined £390,000 by OFSI

The UK’s Office of Financial Sanctions Implementation has issued a Penalty Notice fining the Irish-incorporated company Apple Distribution International Limited (“ADIL”), £390,000 for breaches of the UK’s Russian sanctions.

ADIL was fined for issuing payment instructions to a UK bank, and for failing to cancel those payment instructions. The two payments in June and July 2022 for a total of £635,618.75 were to Okko LLC, a company wholly owned by the designated person JSC New Opportunities.

OFSI took the view that the instructions issued to a UK bank, and the failure to cancel those instructions, amounted to conduct within the UK for the purposes of the jurisdictional reach of the UK’s sanctions. This is in line with older case law that had established that sending instructions into the UK could amount to an offence within the UK.

ADIL self-disclosed the conduct in October 2022. The Penalty Notice was also arrived at by way of an agreed settlement pursuant to OFSI’s new enforcement procedures.

The penalty is also noteworthy because JSC New Opportunities was designated by the UK at 11am on 29 June 2022. The first payment instruction had been made on 6 June but with a value date of 30 June. The second payment instruction was issued on 30 June with a value date of 28 July 2022.

OFSI took the view that there was a “narrow window” in which the first payment could have been stopped, and that it was an aggravating factor justifying enforcement action that a second payment had been ordered. The Penalty Notice also expressly states that OFSI was relying on the “strict liability” enforcement rules that come into effect in 15 June 2022. Earlier payments made to Okko LLC, while it had been owned by a different designated person were also made in breach of the UK’s sanctions, but were not the subject of OFSI’s enforcement action as they took place before the coming into force of the “strict liability” rules.

OFSI also stated that despite the failings of the external screening provider used by ADLI, it was ultimately ADLI’s responsibility as the payment issuer, to ensure compliance with the UK’s sanctions.

March 26, 2026March 26, 2026 by Mark Handley

Sweden – raids on “large company” and two arrests in sanctions investigation

Sweden’s Public Prosecutor has issued a press release making public raids conducted this morning at the premises of an unnamed “large company” in Sundsvall.

Two unnamed “people in senior positions” have also been arrested on suspicion of aggravated sanctions violations.

The press release does not include information on the suspected breaches.

Given the web links to information on Sweden’s Russian sanctions included in the press release, the investigation is very likely to relate to suspected breaches of the EU’s Russian sanctions.