Financial Sanctions – European Sanctions Enforcement

September 4, 2026September 4, 2026 by Mark Handley

Luxembourg – CSSF imposes fine for AML and sanctions compliance violations

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“.

September 3, 2026September 3, 2026 by Mark Handley

Czechia – police refer sanctions evasion case to prosecutors

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).

September 2, 2026September 2, 2026 by Mark Handley

UK – OFSI imposes fine of £4.73m on investment bank

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.

August 24, 2026August 24, 2026 by Mark Handley

UK and Ireland – TikTok self reports possible sanctions breaches

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.

July 6, 2026July 6, 2026 by Mark Handley

Estonia – details of 5 criminal convictions for sanctions breaches

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.

June 23, 2026June 23, 2026 by Mark Handley

Lithuania – sanctions enforcement statistics and €6.2m in fines for 2025

Lithuania’s Financial Crimes Investigation Service has issued a summary of its work for 2025, as well as a more detailed report (see pages 45-46) that includes the following:

232 suspicious activity reports from financial institutions related to suspected breaches or circumvention of sanctions;
77 of these were reported to other competent bodies in Lithuania or in other EU member states;
45 inspections from the International Sanctions Implementation Commission;
€6,236,375.46m in fines for 2025 across 12 cases;
In addition:
- in 2025, 27 cases were dealt with administratively with fines in these minor cases totalling more than €32,150
- in 2024, 19 cases were dealt with administratively with fines totalling €28,000
- in 2023, 12 cases were dealt with administratively (the value of the fines is not given)

The report also notes that 1 of the cases related to public procurement, 1 to the failure to provide information, 5 to circumvention, and 20 to the use of a bank designated by the EU.

June 17, 2026June 17, 2026 by Mark Handley

UK – OFSI imposes Russian sanctions fine of £1,000,920.59

The UK’s Office of Financial Sanctions Implementation has issued a Penalty Notice against Sabre Global Technologies Limited (SGTL) imposing a fine of just over £1m against this UK entity.

SGTL continued to provide services to JSC Ural Airlines after that entity was designated in May 2022 and after the fact of the designation was communicated to SGTL by its lawyers on the same day.

Three payments were made to SGTL by JSC Ural Airlines between June and September 2022 totalling $906,576.30. These payments were blocked by SGTL’s bank.

In October 2022 SGTL self-disclosed the breaches to OFSI.

The Penalty Notice identified the following breaches:

by invoicing JSC Ural Airlines SGTL made available a financial benefit (and so “funds”) in the form of the discharge of a debt obligation by the airline;
by continuing to provide the airline with access to a product providing travel content up until 6 December 2022, SGTL was making an “economic resource” available to the airline;
by exploring alternative payment routes to avoid the UK, including the making of a “test” payment of $200 to SGTL’s US bank account, SGTL was circumventing the UK’s sanctions in breach of regulation 19.

These breaches, especially the continued offering of SGTL’s product, were assessed as having a value of £2,634,001.54.

OFSI assessed the breaches as being in the “most serious” category given the value, the duration and the efforts at circumvention. The fine was assessed at the maximum of 50% of the value, and then the company obtained a 20% discount to reflect self-disclosure.

The Penalty Notice makes several other “Notes on Compliance”:

“firms must not test, reroute, restructure, or otherwise manipulate payment pathways in order to avoid, evade, or defeat the effect of UK sanctions. Attempts to engineer alternative channels, including staging of payments through third countries, may constitute circumvention and a breach in and of itself. Such conduct will be treated as aggravating and will significantly increase the seriousness of any case“;
“firms must be vigilant in identifying what may constitute an “economic resource” under UK sanctions regulations. Economic resources are assets of every kind, whether tangible or intangible, movable or immovable, which are not funds but can be used to obtain funds, goods, or services. Services that can be exchanged, directly or indirectly, for funds, goods, or services may constitute an economic resource even if they are intangible or provided digitally. In particular, firms should not assume that software, data services, or digital tools fall outside the scope of financial sanctions. A service that enables a designated person or entity to generate revenue, maintain operations, or otherwise obtain an economic advantage may amount to making an economic resource available“; and
“Although it is reasonable for a firm to take some time to assess the nature and extent of the breach, or seek legal advice, this should not delay an effective response to the breach. In practice, firms should contact OFSI early to inform us of a breach or potential breach. Where full disclosure is not possible, firms should make an early disclosure with partial information on the basis that it is still working out the facts and will make a further and full disclosure as soon as possible“.

June 15, 2026June 15, 2026 by Mark Handley

Poland – sanctions enforcement statistics with nearly 2500 cases registered

A lengthy article in the Belarusian Investigative Center on alleged sanctions circumvention regarding Belarusian wood pellets, includes data obtained from the Polish Prosecutor’s office on sanctions enforcement:

187 criminal cases were pending as of mid-2026 for circumvention of sanctions against Belarus and Russia (see our earlier post from May 2026 where the figure was 191);
nearly 2,500 sanctions cases have been registered;
85% of these 2500 cases, or over 2100, concerned Belarus; and
At least 91 criminal proceedings were specifically related to wood-processing products.

June 8, 2026June 8, 2026 by Mark Handley

Latvia – trial begins in significant case for the EU’s Russian sanctions

Further to our earlier post, trial has begun today in Riga of Eduard Tsehoval, the former head of the property known as Moscow House, in Latvia.

The prosecution alleges that Moscow House was ultimately owned or controlled by designated persons, Moscow’s Mayor Sergey Sobyanin, or by President Putin in their respective official capacities.

It is alleged that Mr Tsehoval oversaw the continued collection of rent by Moscow House after the imposition of sanctions, thereby making funds available to designated persons.

If the prosecution is successful on the basis of the property being controlled by President Putin, this case could have significant ramifications in the way Russian state-owned property is treated under the EU’s Russian sanctions.

June 8, 2026June 8, 2026 by Mark Handley

Bulgaria – investigation announced into real estate deal suspected of breaching Russian sanctions

It is being reported that Bulgaria’s Ministry of Justice has ordered an investigation into sales of real estate in Bulgaria by the Russian state enterprise Goszagransobstvennost.

The sales are reported to have been to Valentin Zlatev, former head of Lukoil Bulgaria, and with payment said to have been deferred until the lifting of sanctions.