Financial Sanctions – Page 3 – European Sanctions Enforcement

March 2, 2026March 2, 2026 by Mark Handley

Portugal – Public Prosecutor opens 26 investigations into Russian sanctions breaches

It is being reported that the Portuguese Public Prosecutor’s Office has opened 26 criminal investigations into possible Russian sanctions breaches since the start of the full-scale war in Ukraine.

No further information is provided as to the nature of the alleged offending or the current state of progress of those investigations.

It is also reported that the Security Intelligence Service (SIS) has “been monitoring and assessing presence in Portugal of elements connected, directly or indirectly with Vladimir Putin’s regime”.

March 2, 2026March 2, 2026 by Mark Handley

Switzerland – FINMA revokes licence of merchant bank for AML and sanctions compliance failures

The Swiss financial services regulator has put out a press release announcing its decision, taken several weeks ago, to revoke the licence of MBaer Merchant Bank AG for AML and sanctions compliance failings.

Initially the bank appealed this decision.

In the wake of the US regulator FinCEN announcing that it proposed to name the bank as a “financial institution of primary money laundering concern”, the bank has withdrawn the appeal against FINMA’s decision, and a liquidator has now been appointed to oversee the bank’s liquidation.

February 23, 2026February 24, 2026 by Mark Handley

Sweden – closed criminal investigation into alleged Russian funds transfers

Press reporting of a civil dispute between Sweden’s SEB Bank and certain Russian customers associated with Olga Pavlova, the Vice-Chair of Gazprom, and relating to attempts to transfer SEK 60 million, has revealed that the same transfers had been the subject of now-concluded a preliminary criminal investigation in Sweden.

It is unclear when the investigation took place, or the basis for the conclusion that no crime had been committed.

February 23, 2026February 23, 2026 by Mark Handley

Austria – Financial Market Authority partially suspends crypto exchange over lack of AML and sanctions compliance officers

Austria’s Financial Market Authority has announced that its has partially suspended its approval for KuCoin EU Exchange GmbH under the EU’s Markets in Crypto Assets regulations.

The suspension means that KuCoin is unable to take on new customers, conclude new contracts, or offer new services.

The suspension is based on the the loss, without replacement, of a Anti-Money Laundering Officer and a Sanctions Compliance Officer.

The FMA has stated that the suspension will remain in place while those positions remain unfilled.

February 20, 2026February 20, 2026 by Mark Handley

Netherlands – DNB fines imposed on payment services provider upheld on appeal

Further to our earlier post, a payment services provider has brought a further appeal against fines imposed upon it by the Dutch National Bank.

In the previous appeal the original DNB fines of €1.1m and €625,000 had been reduced to €850,190 and €562,500.

Those fines have been upheld in this further appeal.

The defendant company, which had self-reported itself, and which operates ATMs had sought to argue that it was the banks and debit/credit card issuers who had the sanctions screening and due diligence obligations, and that its own self-report could not be used in evidence against it on the basis that it could not be required to incriminate itself.

The court dismissed these objections. The self-reporting had been voluntary and not required and, as a payment service provider, the sanctions compliance obligations also applied to the appellant.

February 20, 2026February 20, 2026 by Mark Handley

Netherlands – sanctions fine from Financial Markets Authority upheld but reduced on appeal

The Rotterdam District Court has issued its decision in an appeal against a fine imposed by the Dutch Financial Markets Authority (the “AFM”).

Three related fine were initially imposed in 2023 valued at €31,000, €94,000 and €31,000 for a total of €156,000. The fines were for a mixture of compliance failings including, AML, terrorist financing and sanctions. The sanctions compliance failures were a failure to screen customers between 2017 and 2022.

The Claimant, a manager of seven real estate investment funds, appealed against this decision, including (amongst others) on the basis that the fine in relation to sanctions should be struck down because none of the customers were actually subject to sanctions.

The court upheld the fine noting (in machine translation):

“The fact that the AFM’s investigation has shown that the clients of the investment institutions … have not been … on a sanctions list does not detract from the seriousness of the violations either. This circumstance is not relevant to the legal obligations of [Claimant] as gatekeeper in the investigation of those clients and the source(s) of their funds, in order … to comply with the Sanctions Law. The assertion that the [Claimant] often knows the clients personally and that the risks were kept to a minimum … do not detract from this either”.

The fine was, however, reduced by 10% (for a revised total of €148,500) because the enforcement proceedings had taken longer than the 2 years permitted under Dutch law.

February 13, 2026February 13, 2026 by Mark Handley

Latvia – prosecution for providing IT services to Russian company

The State Security Service of Latvia has announced the prosecution of an individual for providing programming services to a Russian company.

This is the fifth recent prosecution in Latvia either in relation to the provision of prohibited services under Regulation 833/2014, or the provision of services to a designated person with the services treated as an “economic resource” that breaches the imposed asset freeze (see October 2025, October 2025, December 2025, and December 2025).

The individual is also being prosecuted on the basis that his salary was paid into Alfa-Bank, which is a designated person under the EU’s sanctions, and that this constitute making funds available to that designated person.

February 4, 2026February 4, 2026 by Mark Handley

United Kingdom – investigations into possible breaches of the Cyber sanctions regime

It is being reported, following a Freedom of Information request to HM Treasury, that the UK’s Office of Financial Sanctions Implementation has between 1 and 5 investigations ongoing in relation to possible breaches of the asset freezes imposed by the UK’s Cyber sanctions regime.

The breaches are all said to relate to the financial services sector, but no further information was released so as to not prejudice ongoing or future investigations.

The report notes that an earlier Freedom of Information request was refused but an internal review lead to the release.

February 4, 2026February 4, 2026 by Mark Handley

Czechia – investigation into alleged breach of designated person’s asset freeze

It is being reported that the Czech police are investigating a potential breach by Ramzan Kadyrov of the asset freeze imposed on him since his 2014 designation under the EU’s Russian sanctions.

It is alleged that a valuable thoroughbred horse was taken from Czechia, although the current whereabouts of the horse are unknown.

The owner had previously claimed that the horse had been stolen.

The investigation has involved support from authorities in Poland, Germany, Bulgaria, Austria, and France.

January 27, 2026January 27, 2026 by Mark Handley

United Kingdom – OFSI fines bank £160,000 for Russian sanctions breaches

The UK’s Office of Financial Sanctions Implementation (“OFSI”) has issued a Penalty Notice to the Bank of Scotland fining the bank £160,000.

The bank opened an account for a designated person in February 2023 and then allowed 24 transactions to and from that account to take place between 8 and 24 February totalling over £77,000.

The bank’s screening system missed the fact that the person was designated, using the spelling in the person’s passport that had a different transliteration from cyrillic than used in the UK’s Consolidated List. One of OFSI’s complaints in the Penalty Notice is that the screening tool was insufficiently able to create a “match” despite the spelling variations.

The designation was first identified because the person was identified as a PEP and adverse media searches then revealed the designation. This was not then escalated to be resolved.

OFSI also noted that the in-house training to the Bank’s staff “was out of date and did not reflect risks associated with the contemporary sanctions landscape, such as the heightened risk posed by Russia sanctions post-2022”.

After an investigation into a different account, the Bank identified this particular account as belonging t a designated person and reported a suspected breach to OFSI on 10 March 2023 and an actual breach to OFSI on 16 March 2023.

The fine was first set at £175,000, including a 50% discount for prompt self-reporting, but this was reduced by OFSI, after further representations from the bank, to £160,000.

In the Penalty Notice’s “Notes on Compliance” attention is drawn to the failure to use a sufficiently robust screening tool, the lack of a clear escalation procedure, and the poor training.

The Penalty Notice does not name the designated person, but similarities indicate that this notice relates to the UK’s conviction of Dmitri Ovsiannikov (see our earlier post).