Financial Sanctions – European Sanctions Enforcement

November 5, 2026November 5, 2026 by Mark Handley

Belgium – investigation into suspected breaches of Myanmar sanctions

It is being reported that Belgium’s Federal Public Service (FPS) Finance is investigating whether breaches of the EU’s Myanmar sanctions have taken place.

The investigation arises out of Monde Selection, the consumer goods awards company, including products in its award selection made by a Myanmar beverage company owned by sanctioned state-owned companies.

The company says it has severed all contact and revoked awards issued as well as removing the products from its website. A spokesperson is quoted as saying that it was unaware of the sanctioned status of the producer at the time.

It is unclear whether the investigation relates to the receipt of fees from the Myanmar company, or whether the view is being taken that the publicity provided to the sanctioned entity would constitute “economic resources” comparable to an OFSI fine imposed in 2022. In that case the publicity afforded to a sanctioned entity by including its wine in a competition was said to amount to making an “economic resource” available to a designated person.

October 7, 2026October 7, 2026 by Mark Handley

France – five charged with fundraising for designated terrorist group

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.

October 7, 2026October 7, 2026 by Mark Handley

Germany – Public Prosecutor investigates Berlin’s “Russia House”

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“.

October 7, 2026October 7, 2026 by Mark Handley

Lithuania – fine of €418,677 for Belarus sanctions breaches upheld in court

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.

September 15, 2026September 15, 2026 by Mark Handley

Luxembourg – public prosecutors tasked with sanctions circumvention investigation at local subsidiary of Russian bank

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.

September 9, 2026September 9, 2026 by Mark Handley

The blog’s 800th post – fines and jail terms

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.

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.