Fine – European Sanctions Enforcement

August 13, 2025August 13, 2025 by Mark Handley

Iceland – bank fined for sanctions compliance failings

This post is catching up on a previously-missed fine issued on 9 May 2025, and first brought to wider attention by Global Investigations Review.

The Financial Supervisory Authority of Iceland’s Central Bank has fined Fossa fjárfestingarbanka hf for compliance failings including sanctions compliance failings as well as anti-money laundering.

The press release is here, and the more detailed note of the findings and fine is here.

In relation to sanctions the failings were a lack of adequate screening, and a lack of ongoing screening with most files sampled having been screened at onboarding but not subsequently. It is not alleged that these failings permitted breaches of sanctions to take place.

The bank was fined ISK 22,000,000 (approximately €153,000).

Iceland largely adopts the EU’s various sanctions regimes. This is the first example of enforcement in Iceland included in this blog.

August 4, 2025August 4, 2025 by Mark Handley

Guernsey – licence revoked and fines imposed on financial services firm and individual

The Guernsey Financial Services Commission has issued a release regarding the imposition of several fines and the revocation of regulatory authorisations for a firm and an individual.

The firm ITI Trade Ltd was fined £175,000, and Mr Alexi Filatov was personally fined £35,000.

An order has been issued preventing Mr Filatov from holding a regulated position for 2 years and 10 months.

ITI Trade Ltd agreed to surrender its licence.

The compliance failings were first identified by the Commission in 2019, and the firm undertook (or purported to undertake) various remediation programmes (the results of which were doctored for the purpose of submissions to the Commission), before the Royal Court appointed Administration Managers over the firm in July 2022.

The failings relate to a lack of sanctions and AML compliance, due diligence and screening with the Guernsey entity “used to appear to provide investment services from Guernsey, when in reality much of the business was conducted in Russia”.

August 4, 2025August 4, 2025 by Mark Handley

United Kingdom – OFSI imposes a fine of £300,000 for breach of EU Russian sanctions

OFSI has published a Penalty Notice fining a UK company Markom Management Limited (“MML”) £300,000 for breaches of The Ukraine (European Union Financial Sanctions) (No.2) Regulations 2014.

The fine was for issuing a payment instruction to return an overpayment of £416,590.92 to a Russian bank account belonging to a designated person.

The fine was initially set at £400,000, but was reduced through the ministerial review process.

This penalty is noteworthy for a number of reasons:

This enforcement action dates from events in 2018. While underscoring the slowness of OFSI’s enforcement steps it also reinforces the lack of a limitation period for the UK’s sanctions, and the fact that the UK continues to enforce the EU sanctions that were in place before Brexit.
The self-reporting by MML was considered insufficient to trigger a discount to the imposed penalty.
The conduct that warranted the penalty was a person in the UK sending a payment instruction to a bank in Russia to transfer funds to another bank in Russia. This is a reminder of the broad reach of the UK’s criminal jurisdiction when it comes to communications sent in or out of the jurisdiction. This penalty notice sits uneasily alongside the recent civil decision in Celestial Aviation Trading Ireland Ltd & Ors v Volga-Dnper Logistics BV [2025] EWHC 1156 (Comm).

July 22, 2025July 22, 2025 by Mark Handley

Estonia – lengthy custodial sentence for sanctions offences

Estonia’s Office of the Prosecutor has issued a press release regarding an agreed settlement with Pavel Kapustin convicting him of sanctions offences as well as espionage and supplying false information.

The man was sentenced to 6.5 years’ jail and assets valued at €90,000 were confiscated. The press release does not break down the sentence by offence.

The man took orders for luxury goods from Russian customers and arranged for their transport to Russia in breach of the EU’s sanctions.

This is the sixth custodial sentence handed down in Estonia for sanctions offences so far this year.

July 15, 2025July 15, 2025 by Mark Handley

Germany – 5 year sentence for and confiscation of c. €5m for sanctioned cars exports to Russia

As first reported in Global Sanctions, and as per a press release by German Customs, the Marburg Regional Court on 8 July has sentenced an individual to 5 years in jail for exporting luxury cars to Russian breach of the EU’s sanctions.

The man was convicted of 71 separate counts.

The court also confiscated approximately €5m as the gross proceeds of the cars sales.

July 10, 2025July 10, 2025 by Mark Handley

Netherlands – two sanctions judgments: i) individual given 3 years prison sentence; and ii) confiscation of €1m in unlawful profits

The Dutch courts have published two sanctions judgments.

In the first case, the District court of Rotterdam has sentenced an individual to three years in jail.

The individual was convicted for providing technical assistance to a person in Russia or for use in Russia of different computer files containing information on the manufacture of microchips. The files were shares by Google Drive and Telegram between January 2023 and August 2024.

The defendant was acquitted of charges of physically taking similar files to Russia on USB sticks.

On sentencing the judgment stated:

“Providing advice to and sharing technology with Russia is extremely serious. It can contribute to strengthening military or strategic capabilities of that country, which has an impact on Ukraine and can indirectly affect international security and stability. It is therefore a serious offence. … The nature and seriousness of the facts justify a prison sentence of considerable duration. The fact that the files would contain outdated information is irrelevant because this information can be of great value to a country with a (much) lower level of knowledge. It must be prevented that a country at war can benefit in any way from advanced technological knowledge. After all, for that reason, an extensive package of sanctions has also been agreed against Russia, among others“.

In the second case, the District Court of Amsterdam has issued an order confiscating €1,013,956.00.

The unnamed corporate defendant had been provided goods and services in relation to the construction of the Kirch Bridge, and had been convicted on 28 November 2024 (our previous post here), with a fine of €120,000 imposed.

The court calculated that the gross revenue obtained in breach of sanctions was €2,711,085, but allowed certain costs including internal time incurred and the cost of insurance resulting in a final confiscation of €1,013,956.

The effect of this is that revenue of nearly €1.7m obtained in breach of the EU’s sanctions was retained by the convicted company.

July 8, 2025July 8, 2025 by Mark Handley

Malta – fines and prosecutions for sanctions violations

As previously posted Malta’s Sanctions Monitoring Board maintains a page or listing companies that have been subjected to a fine of greater than €800 for sanctions breaches.

The page has now been updated to include the fact of a fine against:

Felicitas Trust Limited based on a “supervisory examination conducted between April and May 2023”; and
Winzon Group Ltd based on a “supervisory examination conducted between February and March 2024”.

No other information is provided, including which sanctions regime was involved.

Separately, the SMB has issued an update on Malta’s implementation of the EU’s Russian sanctions. This notes the completion of 211 inspections, and notes that some of its investigations “are cases advancing through judicial channels”.

No further information is provided on these, presumed, prosecutions.

July 8, 2025 by Mark Handley

United Kingdom – £1.1m penalty for exports to Russia

HM Revenue and Customs has issued a Notice to Exporters reporting on the imposition of a civil compound penalty against an unnamed company for making “goods available to Russia in breach of” the UK’s Russian sanctions.

The penalty is stated to be £1,160,725.67.

No other information has been published on the identity of the offender, the nature of the offending or the goods that were exported, whether there was a self-report, or the nature of the cooperation that secured a civil penalty.

July 3, 2025July 3, 2025 by Mark Handley

Latvia – 91 proceedings to confiscate the “proceeds of crime” arising from EU sanctions breaches

Latvia’s Customs has issued a press release providing details on a recent confiscation proceeding, and providing some data on confiscation proceedings over all.

The press release states that 91 proceedings have been commenced to confiscate criminal property arising from breaches of EU sanctions.

It is noted that to date 57 of these proceedings have resulted in the confiscation of assets totalling €1,935,683.

The particular recent case outlined in the press release relates to the confiscation of a truck and trailer that had been stopped and searched at the Terekhova customs point. Officers suspected that the truck was itself being exported, and an investigation was commenced.

By court decision of 9 June 2025 the truck and its trailer, valued at €52,500, were confiscated.

July 1, 2025July 1, 2025 by Mark Handley

France – financial services regulator fines bank €600,000 for sanctions compliance failings

France’s ACPR has issued a press release making public a fine of €600,000 imposed on Banque Delubac.

The detailed Décision, make clear that the compliance failings predominantly relate to AML and CTF failings, but Complaint 9 relates to sanctions compliance. The ACPR noted a failure by the bank to collect data on directors and beneficial owners for more than a quarter of its business customers. Further, the bank applied no screening at all on transactions valued at below €1,000 between 2020 and 2022/203.

The size of the fine is said to reflect the €3m spent on improving the bank’s compliance, and the bank’s loss for the financial year 2024.