Fine – European Sanctions Enforcement

September 9, 2026September 9, 2026 by Mark Handley

The blog’s 800th post – fines and jail terms

It was only in March that the blog passed the milestone of 700 posts, and now it is at 800. To mark the occasion we are publishing some graphs on the current state of enforcement across Europe.

Fines

The first graph shows (in blue columns) the annual values (in euros) of fines/confiscations/penalties/forfeitures for sanctions breaches across Europe from 2017 to 2026.

The green line is the number of fines in any given year valued at €1 million or more.

With nearly four months to go 2026 is at €115.3m and is on track to surpass both 2024 and 2019 in terms of total value (and 2019 had a single fine of £102m from the UK’s FCA).

What the graph also illustrates is that while 2018-2020 had a small number of very large fines, countries across Europe are now imposing a much higher number of significant fines than before.

Jail terms

The next graph is another way of showing the sea change in enforcement outcomes since 2022.

In the last three years over 175 years of jail time (not including suspended sentences) have been handed down. The adoption and implementation of the EU’s harmonization directive, is only going to reinforce and further drive this trend as more member states take on the power to impose a custodial sentence.

September 9, 2026September 9, 2026 by Mark Handley

UK – HMRC issues £7.4m penalty for supply of goods to Russia

The UK’s HM Revenue and Customs has issued its largest sanctions-related Compound Penalty to date.

The company, Illumina Cambridge Limited, was fined £7,438,840.13 for breaches of the UK’s Russian sanctions.

The published Notice gives limited information on the breaches:

“Between July 2022 and January 2023 Illumina breached regulation 25(1) through their involvement in the supply of sanctioned goods from one overseas company within their corporate group to another overseas company within their corporate group for export to Russia and other destinations“.

Regulation 25(1) prohibits the direct or indirect making available of “restricted goods” or “restricted technology” either for use in Russia, or to a person connected with Russia.

Illumina Cambridge Limited voluntarily disclosed the conduct to HNRC and cooperated with the investigation.

As noted by HMRC “sanctions breaches can occur when UK businesses are involved in supply chains that result in sanctioned goods being supplied indirectly to Russia (or other countries subject to trade sanctions), even when no goods have been exported from the UK“.

This is the third large fine/forfeiture handed out by UK authorities in the last few weeks following the £4.7m fine from OFSI (2 September) and the $5.2m forfeiture from the National Crime Agency (27 August).

September 4, 2026September 4, 2026 by Mark Handley

Luxembourg – CSSF imposes fine for AML and sanctions compliance violations

In an Administrative Sanction published by Luxembourg’s CSSF, a fine of €56,000 was imposed on Stonehage Fleming Luxembourg S.A.

Most of the notice relates to AML compliance failings, but included was a complaint as regards to the resolution of sanctions screening hits and a delay in implementing changes to lists for screening purposes:

“At the time of the on-site inspection, hundreds of name screening alerts had been treated with significant delays and 42 alerts remained unnoticed by the PFS. These delays constitute a breach of the obligations foreseen in Article 3(2) point (d) of the AML/CFT Law and in Article 33(1) of CSSF Regulation No 12-02, as the PFS was unable to identify “without delay” persons subject to restrictive measures in financial matters and therefore apply “without delay” potential restrictive measures in financial matters as the case may be“.

September 3, 2026September 3, 2026 by Mark Handley

Latvia – Customs confiscates €15m in sanctioned goods

A broadcast news story has provided data on the enforcement activity of Latvia’s Customs.

The story reports that:

roughly twice a week a shipment of sanctioned goods to Russia is stopped;
30 cargoes of military goods have been stopped; and
Customs have confiscated €15m in sanctioned goods through its work at inspections at checkpoints, of which roughly €3m has so far been sold.

The new story does not state over what period the confiscations took place.

September 2, 2026September 2, 2026 by Mark Handley

UK – OFSI imposes fine of £4.73m on investment bank

The UK’s Office of Financial Sanctions Implementation has issued a Penalty Notice against Citibank NA in the amount of £4,732,830.58.

This is OFSI’s second largest fine since it was launched.

The fine relates to 970 payments in breach of the UK’s Russian sanctions with a total value of £19,720,127.32 with most of the payments taking place in the months after February 2022.

OFSI have Citibank a 20% voluntary self-disclosure and cooperation credit (and not the permissible 30%). The bank had voluntarily self-reported many of the breaches and payments, but was unaware of £6.9m of the payments being breaches until OFSI started to raise questions.

OFSI also provided Citibank with a 20% discount based on agreeing a settlement, under OFSI’s fairly new settlement methodology.

These discounts, against a starting point where the maximum fine is 50% of the value of the breaches, resulted in the penalty amount. It is worth noting that the new Chancellor has announced plans to increase the maximum fine to 100% of the value of the transfer.

The breaches all related to failings and delay in screening customers, recipients and correspondent banks. While OFSI’s Notice expresses sympathy with the high volume of designations that took place in 2022, it was critical of Citibank’s level of preparedness in the run up to February 2022 and of the high volume of errors including changes in policy that made the prevention of payments more difficult. OFSI also was critical of the time taken for the bank to report that it was holding frozen assets.

September 1, 2026September 1, 2026 by Mark Handley

Netherlands – confiscation of proceeds from sanctions breaches reduced on appeal

Further to our earlier post regarding a 2024 conviction and confiscation, the Hague Court of Appeal has ruled on an appeal by the convicted defendants on the quantum of the confiscation.

The revenue from the criminal transactions was €1,924,579.20, with the first instance court allowing deductions of costs, to arrive at an initial confiscation order in the sum of €298,310. This was in line with the Dutch methodology of confiscating net profit rather than gross profit.

The defendant raised a number of arguments:

1) that there should be no confiscation;

2) that certain costs (transport, packaging, testing, etc) had been improperly not deducted from revenue;

3) that the value of confiscated goods should be credited in favour of the defendant; and

4) that the defendant did not have the financial means to satisfy the confiscation order.

All of these arguments were rejected by the Hague Court of Appeal. Despite this, the Court reduced the sum to be confiscated to €250,195. The Court provided no reasoning, or basis for, this reduction.

August 27, 2026August 27, 2026 by Mark Handley

UK – National Crime Agency agrees forfeiture of $5.2m to resolve sanctions and AML investigation

The UK’s National Crime Agency has issued a press release stating that it has entered into a settlement agreement with ENEX Premium Trading Limited, owned by Nadir Valiyev and registered in St Kitts and Nevis.

The press release states that the settlement involves no admission of criminality by either ENEX of Mr Valiyev.

The allegation that was investigated from 2024 onwards was that ENEX was involved in the shipment of stolen Ukrainian grain. The NCA obtained an Account Freezing Order in November 2024 over sums received from China between July and September 2024. It is those funds which have now been forfeited.

August 3, 2026August 3, 2026 by Mark Handley

United Kingdom – two fines for military export control breaches

On 27 July, the UK’s HM Revenue and Customs issued a “Notice to Exporters” relating to two companies fined £216,530.30 and £20,889.15 respectively.

The companies were not named.

The conduct was not described in any detail and only said to “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”.

The details of why and how these companies were able to secure a resolution via a compound penalty were also not provided, although the Notice says in general terms:

“Compound settlements may be offered where an exporter has:

voluntarily told HMRC about sanctions or export control breaches, and
committed a breach that was inadvertent or due to weaknesses in internal controls”.

July 30, 2026July 30, 2026 by Mark Handley

United Kingdom – £6.4m fine for strategic export control failures

Further to our earlier post reporting on the UK’s investigation into Airbus, HMRC has today issued a Notice to Exporters that Airbus Operations Limited (AOL) has entered into a compound settlement with HMRC under which it will pay a fine of £6,409,388 for offences under The Export Control Order 2008.

This is the largest fine imposed by HMRC under the compound settlement regime, and is another example of the new practice of sometimes naming companies that enter into such settlements.

The offences do not relate to sanctions but to the UK’s strategic export controls regime.

The breaches took place “over a sustained period” before November 2022 and were self-reported by AOL which cooperated with the investigation and has implemented remediation.

The breaches are described in only general terms as follows:

Article 29(2)(a-g) on multiple occasions for failing to keep accurate records of transfers of controlled technology as per the conditions of three of their Open General Export Licences (OGELs)
Article 29(3) on multiple occasions for failing to keep registers in relation to their OGELs
Article 29(2)(i) on multiple occasions for failing to keep accurate records contrary to the conditions of one of their OGELs
a Standard Individual Export Licence (SIEL) on one occasion, relating to a failure of licence conditions

July 20, 2026July 20, 2026 by Mark Handley

Netherlands – investment bank fined €8.5m for compliance failures, including sanctions

The Dutch DNB has issued an administrative fine to ABN Amro relating to compliance failings.

The fine was reduced from €10m to €8.5m as part of a settlement with the bank.

The sanctions element relates to a number of the customers included within the DNB’s investigated sample. As part of the assessment of these client files it was determined that there was an unaddressed risk that some of the clients were involved with dual-use goods with some indicators that the bank’s customers were using intermediaries in high-risk jurisdictions to evade or circumvent the EU’s Russian sanctions. The bank was also criticised for undue reliance on uncorroborated client declarations.