The UK’s OFSI has announced a £5,000 monetary penalty imposed on Svarog Shipping & Trading Company Limited.
The fine was for failing to respond to an information request from OFSI in breach of regulation 74(1)(a) of the UK’s Russian sanctions regulation.
The Penalty Notice states that the request for information was made in the context of a wider “large and complex investigation into suspected breaches” of the UK’s sanctions in relation to Sovcomflot. That investigation is, presumably, ongoing.
In an earlier post, we reported on the October 2023 sentence of an individual to 18 months in jail, and a fine of €200,000 imposed on the company operated by the individual.
It is now being reported that an appeal has been brought by the Dutch Public Prosecution Service (the “OM”) seeking to increase the sentence.
The OM are seeking a three-year custodial sentence, a five-year ban from the individual acting as a director, and confiscation of €72,697.71 of the proceeds of the sanctions breaches.
It is reported that the appeal is based on the deliberate nature of the offending with the export of sanctioned goods to Russia via third countries including the Maldives and Kazakhstan.
There is no appeal in relation to the fine of €200,000 imposed on Woerd-Tech BV.
Further to the earlier post about Estonia having obtained 8 criminal convictions during 2024, we can publish details of the criminal convictions for breaches of the EU’s Russian sanctions that have been published on Estonia’s searchable gazette of published judgments.
As well as one conviction obtained in 2022, below we are publishing summaries of seven of the convictions from 2024 and three from 2025 (not including the conviction made public on 16 April 2025) as well as machine translations of the respective judgments.
The sentences range from fairly small monetary fines up to custodial sentences of 5 years in jail.
The offence was the attempt to export a 3D printer and an electromagnetic positioner. Mr Rafalovich was carrying false papers indicating the goods were destined for an Armenian company, as well as other papers indicating the true recipient to be a Russian company.
2. Judgment of 5 February 2024 – Victor Manilo was convicted and ordered to pay €2,680 as a fine.
The offence was the attempted export of €14,000 in physical currency to Russia.
3. Judgment of 14 February 2024 – Galina Sergejenkova was convicted and ordered to pay €3,960, such payment suspended for a probationary period of 18 months. A separate payment of costs and a penalty of €1,434.96 were to be paid straightaway.
The offences were two attempts to transport physical currency (of €900 and €1,000 respectively).
4. Judgment of 27 February 2024 – Evgeniy Kozlovtsev was convicted and given an eight month sentence suspended for a probationary period of 18 months. He was also ordered to pay a penalty and costs of €1,430.
The offence was the attempted export to Russia of two bottles of wine greater than the €300 luxury threshold. It was the man’s second attempt at such exports.
5. Judgment of 8 March 2024 – Aleksei Bond was convicted and given a five month prison sentence suspended for a probationary period of 18 months. He was also ordered to pay a penalty and costs of €1,555.
The offence was the attempted export of a luxury watch valued at €13,900 to Russia.
6. Judgment of 27 March 2024 – Lev Pylkin was convicted and ordered to pay a penalty of €1,190, as well as confiscation of the cash he attempted to export to Russia.
The offence was the attempted export of €2,560 in physical currency across the border to Russia. He had previously attempted to export cash at which time the details of the offence had been explained. The judgment is the dismissal of an appeal against the conviction and sentence.
7. Judgment of 17 October 2024 – Ruslan Sibilev was convicted and ordered to pay a fine of €79,557.50 as well as confiscation of a large number of rifle scopes, binoculars and other equipment.
The offences were committed through the acquisition of a range of sanctioned goods from a Portuguese company and an Austrian company, with Sibilev acting to coordinate further transport for the export of the goods to Russia. The orders were placed between May 2022 and April 2023. The total value of the goods ordered was nearly €1 million.
8. Judgment of 16 December 2024 – Oleg Osipov was convicted and sentenced to 8 months in prison suspended for a probationary period of 18 months. He was also ordered to pay €13,230, including 100% of the fee earned as part of the sanctioned transactions.
The offences were committed through Osipov providing a brokering service for the export of luxury goods to buyers in Russia between May and July 2023. The goods included electrical goods, phones, alcohol, navigation systems and various automotive parts. Osipov contracted with others to deliver the goods and took a brokering fee for arranging the transactions.
9. Judgment of 14 February 2025 – Demyan Belyakov was convicted and sentenced to 5 years in jail and ordered to pay €8,231 in costs and other penalties. In addition a large volume of goods were confiscated.
The offences were committed through the actual and attempted export to Russia of hundreds of silencers and firearm flash suppressors between February and June 2024.
10. Judgment of 20 February 2025 – Andrei Klychkov was convicted and sentenced to serve two months in prison plus a further period of 2 years and 10 months suspended for a probationary period of 4 years. €5,000 was also confiscated and he was ordered to pay costs of €2,581.
The offences were committed by the attempted export of parts for firearms, to Russia.
11. Judgment of 21 March 2025 – Aleksandr Ivantsov was convicted and sentenced to 4 years, 11 months and 27 days (after deducting 3 days of pre-trial detention) suspended for a probationary period of 5 years and other conditions including a requirement for prior permission to be away from his house for more than 15 days, and permission to leave Estonia. He was also ordered to pay €2,215 and had 70,550 rubles, and other goods, confiscated.
The offence was committed by the attempted export of six pairs of night-vision binoculars.
This case is related to that above for Ruslan Sibilev with Mr Ivantsov being one of the people used to try and physically carry the goods across the border into Russia.
The Estonian authorities have secured a guilty plea as part of a plea deal by an individual who accepted funds from a designated person.
The accused, Tatjana Sokolova, received payments into Russian bank accounts from “The Foundation for the Support and Protection of the Rights of Compatriots Living Abroad” – a designated person under the EU’s sanctions.
The funds were withdrawn and carried into Estonia in person. The money was to be used to fund the defence of another individual who was being prosecuted for crimes against the Estonian state.
The sentence is for 360 hours of community service, with the 12-month unserved part of a 16-month prison sentence to be suspended pending completion of the community service.
Cash of €10,000 found when Sokolova was arrested has been confiscated and she was ordered to pay €1389 in court costs.
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:
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”.
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.
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:
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.
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.
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.
