Fine – European Sanctions Enforcement

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 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.

May 6, 2026May 6, 2026 by Mark Handley

Netherlands – confiscation orders issued against company and individual convicted in 2024 of sanctions offences

Further to an earlier post relating to convictions of an individual and company obtained in October 2024 for supplying aircraft parts to Russian customers in breach of the EU’s sanctions, the Rotterdam Court has now ruled in the confiscation proceedings brought by the prosecution.

In the confiscation judgement against the (unnamed) company, the court ordered the confiscation of €165,826.

The court held that the revenue obtained from the sanctions breaches was €2,901,194, but allowed as “deductible costs” 82% of this amount, or €2,385,739. This is in line with the Dutch approach of allowing the convicted parties to break even on the unlawful transactions by confiscating not the illegally-obtained revenue (which the CJEU has held is a permissible approach), but rather the pure profit element.

The profit element was accordingly assessed as €515,455 which was divided between the convicted person and the convicted company.

In the second confiscation judgment against the individual, the same analysis was undertaken with the balance of €349,629 from the profits attributed to the individual. The judgment states that a further 599 days of jail time would be added to the existing sentence in the event that the confiscation order is not satisfied.

May 1, 2026May 1, 2026 by Mark Handley

Germany – publication of the latest 6-monthly sanctions enforcement update

The German authorities have published the third instalment of their 6-monthly updates on their current enforcement actions.

The report highlights:

The conviction on 2 March 2026 of two individuals relating to the export of 111 luxury cars to Russia, with €20m confiscated, and jail sentences of 6 years and 2 years (the latter suspended). See our previous post.
Raids conducted in November 2025 and the ongoing investigation into the suspected export of machine tool to Russia value at €1.7m. The report confirms that the investigation by the Stuttgart Public Prosecutor’s Office and the Stuttgart Customs Investigation Office remains ongoing. See our previous post.
An investigation into five suspects for the organized circumvention of sanctions against Russia. A company is alleged to have exported technical equipment and accessories worth c. €689,000 to a company in Russia via third countries. The investigation started in February 2025 and is being conducted by the Essen customs investigation office, is ongoing. See our previous post.
The prosecution of a 41-year old suspected of exporting 236 cars to Russia valued at approximately €18.86m. See our previous post.
The arrest of five suspects on 2 February suspected of 16,000 illegal deliveries to 24 listed Russian arms companies of good worth at least €30m. The prosecution was supported by the Federal Intelligence Service (the BND). See our previous post.
On 27 March raids conducted on 14 premises in the Rhine-Main region against two companies suspected of exporting machine parts and chemicals to Russia. A third company is said to have been involved in the alleged use of a transport and logistics companies to try and circumvent the EU’s sanctions. See our previous post.
The ongoing investigation into a member of the Saxon state parliament for allegedly falsifying the export declaration in relation to a telescopic handler rather than stating the correct destination of Belarus. Searches were conducted at residential and business premises. See our earlier post.

The update also reports on a decision of the CJEU from 5 February 2026 upholding the seizure by German customs of a Mercedes car purchased in Russia and imported to Germany. The CJEU held that the single specific import did not need to “generate significant revenue for the Russian state”, so long as the general category of goods did.

Further cases noted previously in the blog over the last few months, but not included in the report are:

an investigation from February 2026 in relation to the import of goods valued at over €4m from Russia;
an investigation made public in January 2026 into the use of RussPost to export goods to Russia;
reporting from January 2026 into a mutual legal assistance request made to Ukraine as part of an investigation into the suspected export of drone parts to Russia;
the arrest in January 2026 of two people on suspicion of making available funds and economic resources to the Donetsk and Luhansk People’s Republics;
an investigation made public in December 2025 by the Munich Prosecutor’s Office into alleged export of 50 luxury cars valued at over €10m; and
raids in November 2025 in relation to the suspected export of 346 cars to Russia.

May 1, 2026May 1, 2026 by Mark Handley

Estonia – individual charged and settlement with a related company as part of Russian sanctions investigation

Further to our earlier post, the Estonian Public Prosecutor has charged Oleg Bessedin on suspicion of:

“transmitting sanctioned Russian TV programs and content via TV and social media channels controlled by him in Estonia and making the sanctioned content available to other channels as well”.

He is also charged with non-violent offences against the independence, sovereignty and territorial integrity of Estonia.

As part of the same investigation, the Prosecutor’s Office reached a settlement with an unnamed legal entity as part of which that entity made a charitable donation of €4000 to a Ukrainian support charity.

May 1, 2026May 1, 2026 by Mark Handley

Latvia – company liquidated and director fined, and second company fined for Russian sanctions breaches

It is being reported that the Latvian authorities have entered into settlement agreements with two companies and a director of one of the companies in relation to resolving prosecutions for breaches of the EU’s Russian sanctions.

The director of the company to be liquidated was fined €10,140 and the second company was fined €17,940.

The first company (unnamed) had accepted an order to ship to Russia Buchholz relays and control relays designed to protect transformers, with a total value of €161,352.

The exporter approached a customs broker (the second unnamed company) to assist with the shipments to Russia. The broker was not told, and nor did it make enquiries, about the prohibited status of the goods.

The shipment did not proceed, but was stopped after an export declaration was made at the Riga Free Port.

April 21, 2026April 21, 2026 by Mark Handley

Poland – company exporting luxury cars to Russia fined c. €4.7m

Poland’s National Tax Administration has fined a company based in Małopolska and run by Belarusian citizens PLN 20,000,000 – or approximately €4,726,000. The fine is administrative, and was the maximum allowable fine.

The company had exported over 100 luxury cars to Russia via Lithuania and Belarus in breach of EU sanctions.

The total value of the cars is said to have been PLN 49m. The press release states that “The evidence gathered indicates that the company’s managers acted knowingly and deliberately participated in the circumvention of sanctions”.

The press release does not mention if proceedings are also being brought against the individuals involved or if the company will be subject to a confiscation of its profits.

April 17, 2026April 17, 2026 by Mark Handley

France – owner of seized tanker admits no evidence of flag status and pays fine to secure release

Further to our earlier post, the owner of the “shadow fleet” vessel the MV Deyna, agreed in a Marseilles Court on Wednesday to pay an undisclosed fine for the release of the vessel.

The owner admitted that it had no evidence to support the vessel’s alleged Mozambique flag status.

Upon payment the vessel was released and is now reported to have left French waters.

April 13, 2026April 14, 2026 by Mark Handley

France – cement maker Lafarge and eight executives convicted of sanctions and terrorist financing breaches

Further to our earlier posts, a court in Paris had today handed down judgment in the long-running Lafarge prosecution.

The company has been convicted of breaches of the EU’s Syrian sanctions as well as terrorist financing and has been fined €1.125m as well as a separate fine of €4.57m for breach of sanctions.

Of the executives also being prosecuted:

– Bruno Pescheux (former director of the Syrian cement factory) received a 5-year jail term and was fined €225,000;

– Bruno Lafont (former Lafarge CEO) was sentenced to 6 years in jail and fined €225,000;

– Christian Herrault (former deputy Managing Director) was sentenced to five years in jail and fined €225,000;

– Frederic Jolibois (successor to Pescheux) was sentenced to three years in jail, two of which were suspended, and fined €80,000;

– Jacob Waerness was sentenced to 18 months in jail and fined €20,000 and a ban from entering France;

– Ahmad Al Jaloudi was sentenced to 2 years in jail and fined €20,000 and a ban from entering France;

– Amro Taleb, a Syrian intermediary, was sentenced to 3 years in jail and fined and fined €60,000 and a ban from entering France;

– Firas Tlass, tried in absentia, was convicted and sentenced to seven years in jail with a €225,000 fine and a ban from entering France.

It appears that a decision on the confiscation of the proceeds of crime in this case is awaited. The prosecution was seeking confiscation of €30m.

Some of the individual defendants have already indicated their intention to appeal.

April 1, 2026April 1, 2026 by Mark Handley

United Kingdom – Irish subsidiary of Apple fined £390,000 by OFSI

The UK’s Office of Financial Sanctions Implementation has issued a Penalty Notice fining the Irish-incorporated company Apple Distribution International Limited (“ADIL”), £390,000 for breaches of the UK’s Russian sanctions.

ADIL was fined for issuing payment instructions to a UK bank, and for failing to cancel those payment instructions. The two payments in June and July 2022 for a total of £635,618.75 were to Okko LLC, a company wholly owned by the designated person JSC New Opportunities.

OFSI took the view that the instructions issued to a UK bank, and the failure to cancel those instructions, amounted to conduct within the UK for the purposes of the jurisdictional reach of the UK’s sanctions. This is in line with older case law that had established that sending instructions into the UK could amount to an offence within the UK.

ADIL self-disclosed the conduct in October 2022. The Penalty Notice was also arrived at by way of an agreed settlement pursuant to OFSI’s new enforcement procedures.

The penalty is also noteworthy because JSC New Opportunities was designated by the UK at 11am on 29 June 2022. The first payment instruction had been made on 6 June but with a value date of 30 June. The second payment instruction was issued on 30 June with a value date of 28 July 2022.

OFSI took the view that there was a “narrow window” in which the first payment could have been stopped, and that it was an aggravating factor justifying enforcement action that a second payment had been ordered. The Penalty Notice also expressly states that OFSI was relying on the “strict liability” enforcement rules that come into effect in 15 June 2022. Earlier payments made to Okko LLC, while it had been owned by a different designated person were also made in breach of the UK’s sanctions, but were not the subject of OFSI’s enforcement action as they took place before the coming into force of the “strict liability” rules.

OFSI also stated that despite the failings of the external screening provider used by ADLI, it was ultimately ADLI’s responsibility as the payment issuer, to ensure compliance with the UK’s sanctions.