Fine – European Sanctions Enforcement

April 10, 2025April 10, 2025 by Mark Handley

United Kingdom – export control compound penalties issued totalling £3.7m

Yesterday the UK’s HMRC issued a Notice to Exporters publishing three recent compound penalties issued to exporters.

In line with HMRC policy when agreeing to a compound penalty resolution, the information provided on the offending, the offender, and the co-operation provided is limited, although in this instance it is specified that the penalties do not relate to sanctions breaches. The detail available states:

The settlements relate to unlicensed exports of military-listed goods and related activity prohibited by The Export Control Order 2008 and contrary to The Customs and Excise Management Act 1979. These do not relate to sanctions offences.

The 3 settlements agreed with UK companies were:

January 2025 – £10,900.00 was paid for export license breaches in relation to the export of military goods controlled by The Export Control Order 2008
February 2025 – £431,232.20 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008
February 2025 – £3,231,762.40 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008“.

April 8, 2025April 8, 2025 by Mark Handley

Luxembourg – CSSF issues fine for AML and sanctions compliance failings

A fine imposed by Luxembourg’s financial services regulator on the Luxembourg subsidiary of the Allianz Group has become public after a court dismissed an appeal.

The fine of €283,000 was first imposed on 25 March 2022, but only published on 4 April 2025 after the conclusion of the court challenge.

One of the compliance issues identified included failures to “provide evidence of complete initial and ongoing name screening against … sanctions lists”.

April 2, 2025April 2, 2025 by Mark Handley

Switzerland – updated enforcement statistics with 9 new convictions since September 2024

Switzerland’s SECO has given an update on its ongoing enforcement actions.

It has received 600 reports of suspected sanctions breaches, and it has opened 68 penalty proceedings, of which 24 have resulted in final fines.

As per our earlier post, as of September 2024 the figure was at 15 final convictions, meaning that another 9 have been added since then.

No figure has been given for the penalties imposed.

March 21, 2025March 21, 2025 by Mark Handley

United Kingdom – OFSI fines Moscow subsidiary of UK law firm £465,000

The UK’s OFSI has published a penalty notice imposing a £465,000 fine on Herbert Smith Freehills CIS LLP (“HSF Moscow”) – a UK LLP which operated as the Moscow office of the law firm Herbert Smith Freehills (“HSF”)

The fine was reduced by half due to prompt self reporting by HSF (all the breaches had been reported by 15 July 2022) and further co-operation in the form of the conduct of an internal investigation.

The breaches of the UK’s sanctions were all done by HSF Moscow between 25 and 31 May 2022. The breaches arose from six payments made to designated persons with a total value of £3,932,392.10. The six breaches were:

a payment into a bank account held at Sberbank (a designated bank) to clear an overdraft;
Payment of three invoices valued at £3,903.76 for insurance issued by Sovcombank Life, a wholly-owned subsidiary of Sovcombank (a designated bank);
Payment of £13,216.32 as a redundancy payment to an employee’s bank account held at Sberbank; and
Payment of £3,915,232.31 into an account held by Alfa-Bank (a designated bank), although the transfer was swiftly reversed.

This case emphasizes above all the approach that OFSI takes in relation to accounts held at designated banks. In the view of OFSI payments into such accounts, albeit accounts held by non-designated persons, will amount to making funds available to a designated person.

In relation to the payment to a subsidiary of a designated person, OFSI also emphasizes the importance of appropriate due diligence to understand possible issues of ownership and control.

March 5, 2025March 17, 2025 by Mark Handley

UK – compound penalty of £374,326.07 for unlicensed exports of dual-use goods

The UK’s HM Revenue and Customs has published a compound penalty of £374,326.07 against an unnamed UK company for “unlicensed exports of dual-use goods and failure to declare a licence to customs”.

No further details were provided as to the nature of the conduct or the basis for offering a compound penalty rather than a prosecution.

February 28, 2025February 28, 2025 by Mark Handley

United Kingdom – HMRC has opened 65 trade sanctions investigations since 2022

In a letter written from the UK’s HMRC (the body with primary responsibility for the criminal enforcement of trade sanctions) to Parliament’s Treasury Select Committee, HMRC has provided significant information on its recent enforcement efforts.

Year	Number of investigations opened
2021	0
2022	14 (all relating to Russian sanctions)
2023	22 (20 relating to Russian sanctions)
2024	29 (27 relating to Russian sanctions)

Of those 65 investigations, HMRC has confirmed that 30 remain live of which 27 relate to Russian sanctions.

The letter tabulates the six fines imposed to date for breaches of the Russian sanctions, and in relation to the largest single fine of £1,000,000 imposed in August 2023 (see our earlier post), the letter notes that this fine relates to “brokering and technical assistance” and not to an actual export.

HMRC’s letter also states that a previously published compound penalty of £1,000 from September 2023 (see our earlier post) was actually for a breach of the UK’s Iran sanctions despite being described at the time as “relating to the attempted export of Dual Use goods”.

HMRC’s letter also states that in October 2024 it referred a case for possible prosecution to the Crown Prosecution Service.

February 24, 2025February 24, 2025 by Mark Handley

Netherlands – updated Russian sanctions enforcement statistics

Updated enforcement statistics are being reported (here behind a paywall, and here in summary) for the Dutch Fiscal Intelligence and Investigation Service (FIOD) and from Dutch Customs.

FIOD is reported to have conducted 30 cases in the three years since February 2022, with six resulting in convictions, and twenty investigations ongoing.

Customs are reported to have started 80 cases, with 16 ongoing, and 64 settled with fines of between €500 and €200,000.

February 20, 2025February 20, 2025 by Mark Handley

Sanctions enforcement in 2024: Europe vs the US

In 2024, probably for the first time ever, Europe (meaning the EU, UK, Switzerland and Norway), imposed and obtained a greater number of fines and convictions; a higher total value of fines; and also a higher single largest fine, for sanctions breaches than those imposed by the authorities in the United States.

The US figures combine the enforcement actions taken by OFAC and BIS, as well as criminal convictions secured by the DOJ.

The European figures are taken from this blog.

The US obtained 52 successfully-concluded enforcement actions, while Europe secured 118.

The US (OFAC and BIS combined) imposed fines equivalent to €56.8m, while Europe imposed a total of €88.5m.

The single largest US fine was $20m in relation to Iran sanctions. The largest fine in Europe was the UK’s £29m imposed on Starling Bank.

February 17, 2025February 17, 2025 by Mark Handley

Netherlands – company settles with prosecution and fined €120,000 for Crimean exports

The District Court in Amsterdam has issued a judgment arising from the export of machinery from the Netherlands to Crimea in 2016 and 2017 for use in the construction of the Kerch Bridge.

The company (a B.V. unnamed in the judgment) reached a settlement with the prosecution, whereby no defence was advanced, no appeal would be lodged, and the company agreed to pay the fine of €120,000.

The court found that the prosecution case was made out, and confirmed the terms of the settlement and the proposed fine.

The judgment does not mention any confiscation of the proceeds of crime.

Judgments have also been released in relation to the related prosecutions of two individuals (here and here), both of whom were acquitted.

January 6, 2025 by Mark Handley

Finland – sanctions enforcement statistics: over 900 investigations, hundreds of fines and dozens of convictions

Press reporting in Finland has provided an update on Finland’s sanctions enforcement.

The update provides:

over 900 preliminary investigations commenced by Finnish Customs:
- 13 started between 2018 and 2021;
- 306 started in 2022;
- 492 started in 2023; and
- 83 started in 2024 (January to September, with an uncertain number since then)
“More than half” involved minor regulatory offences and have been resolved by monetary fines without recourse to the court system. These cases are further described as: “The fine cases mainly concern private individuals who have exported small quantities of banned goods across the border. Private individuals have exported, for example, luxury goods, not equipment needed by the military“.
“Dozens” of convictions and fines imposed by the courts for more serious offences. These are described as: “characterized by planning, systematicity and the pursuit of significant financial gain. Most often, they involve equipment needed on the front line. … The perpetrators in such cases are typically small or medium-sized export or logistics companies“.

The report provides no further details on the precise number of fines, the amount of fines, or other sentencing involved.

A separate report notes that the Finnish Navy has established a controlled area in the Gulf of Finland where Russian-linked vessels are inspected. This de facto maritime detention zone is encircled by Finnish naval forces and that currently 20 Russian “shadow fleet” vessels are “under scrutiny, with several facing potential long-term detention“.