Financial Sanctions – European Sanctions Enforcement

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.

May 28, 2026May 28, 2026 by Mark Handley

Estonia – conviction for supplying press articles to Russian designated person

The District Court in Viru has convicted Aleksei Toom of sanctions offences and sentenced his to nine months in prison suspended for one year conditional upon no further offending.

Mr Toom’s conviction was for authoring over 100 press articles for a media outlet that is controlled by Dmitry Kiselyov, a designated person under the EU’s Russian sanctions.

Mr Toom’s employment had ended in October 2020, but he continued to write under the pen name Paul Tomson until December 2023.

The Prosecution, and the court, took the view that such articles were an economic resource, and that Russia Today’s portal, Baltnews, was controlled by Mr Kiselyov.

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.