Fine – European Sanctions Enforcement

July 6, 2026July 6, 2026 by Mark Handley

Estonia – details of 5 criminal convictions for sanctions breaches

The Estonian case law website has made available a number of further judgments relating to convictions for sanctions offences:

Case 1. Judgment dated October 6, 2025

This case was the prosecution of Mati-Dmitri Terestal (see our earlier post). It was alleged that he, and another, had made economic resources and find available to a designated person who was the head of Yle1 (a Russian state-owned media outlet). It was alleged that Terestal continued to operate the media outlet after it had been closed, through a front entity and had continued to provide economic resources in the form of technical equipment, and other assets.

It was also alleged that by hiring staff for the company this was making economic resources available to Yle1, as was the creation of web domains.

The County Court had convicted Terestal in January 2025, and sentenced him to 2 years and 4 months, this was suspended for three and a half years. He was also fined €7882.92.

The District Court disagreed with the County Court on a number of issues (including whether hiring staff without more amounted to the making available of an economic resource, but upheld the conviction. The sentence was unchanged.

The decision includes a discussion of the characteristics of control for asset freeze purposes.

Case 2. Judgment dated January 21, 2026

The prosecution entered into an agreement with the defendants that was upheld by the court following guilty pleas by the defendants.

The defendants (a company and a director that company) had set out to create a fake network of transactions and sales in order to import bitumen from Russia in breach of the EU’s sanctions. The fake transactions involved front companies in a range of jurisdictions including Kazakhstan and Hong Kong. One member of staff (who was either not prosecuted or separately prosecuted) had the role of maintaining a watching brief on changes to the EU’s sanctions in order to develop changes to the methodology for masking the Russian imports.

The company, Keystone Shipping OÜ, was fined €250,000, ordered to pay costs of €61,928.18 and had bitumen valued at €179,200 confiscated.

Andrey Kolesnikov, the sole director of the company, was fined €32,110 and costs of €1,329.

Case 3. Judgment dated March 6, 2026

The case was an appeal to the District Court from a judgment of the County Court which had found two men guilty of attempting to export a BMW car to Russia in breach of the EU’s sanctions against the export of luxury goods. Vladimir Palamarchuk was fined €3000 and Igor Palamarchuk was fined €2000. In addition the car, valued at over €50,000, was confiscated as the proceeds of crime.

The appeal, which was largely based on whether the car exceeded the 50,000 threshold, was denied and the fines and confiscation upheld.

The judgment relied on the EU’s FAQs in relation to the process for determining the price of an exported good.

July 6, 2026July 6, 2026 by Mark Handley

France – guilty plea for Tagor tanker owner leads to €1m fine and release

Further to our earlier post regarding the detention by the French authorities of the oil sanctioned shadow fleet tanker, the Tagor, on 2 July, the company owning the vessel pleaded guilty in a Brest court to failing to be flagged and a refusal to comply with an order.

The company was fined, and paid, a fine of €1m. Upon payment the vessel was released and the is now sailing for Istanbul.

Our European Vessel Seizure Tracker has been updated.

July 2, 2026July 6, 2026 by Mark Handley

Finland – conviction for Russian truck exports with 3 years and 8 months jail and €6.6 million confiscated

Further to our earlier posts (here, and here, and here), Risto Riihimäki has been convicted of aggravated sanctions breaches for his role in the export of 135 trucks to Russian in breach of the EU’s sanctions.

The trucks were declared to be transiting through Russia, but that was actually their final destination.

Mr Riihimäki was the CEO of the company Idän liikennevälitys IL Oy, and he has been sentenced to jail for three years and eight months, just below the 4 year maximum sentence for the offence under Finnish law.

In addition, the court has imposed confiscation order for €608,275 against Mr Riihimäki as the proceeds of crime, and a confiscation order against the company for profits it obtained from the exports in the sum of €6m. The company was also fined €10,000.

Although two other employees had originally been the subject of the investigation, ultimately they were not charged.

The conviction and sentence remain subject to appeal.

June 29, 2026June 29, 2026 by Mark Handley

UK – compound penalty of £569,157 imposed on named energy company

The UK’s HM Revenue and Customs has announced the imposition of a compound penalty of £569,157 on Petrofac Facilities Management Limited.

This is the first time, in a long time, that HMRC has named the recipient of a compound penalty.

The breaches took place in 2022 and 2023 with the company supplying prohibited goods to individuals connected with Russia and also providing technical assistance in relation to those goods.

The company subsequently self-reported and cooperated with the investigation.

The change in naming policy is addressed:

“Naming those involved brings us into line with other enforcement partners whilst sending a clear message on the consequences of breaching sanctions rules.”

The Notice further states that “Where appropriate, HMRC will now include naming as a condition when offering a compound settlement for strategic export and sanctions offences“. It appears that naming will now become more common if not done universally.

The Notice also gives helpful guidance on when HMRC will consider a compound penalty rather than prosecution, noting that a penalty will only be pursued where HMRC considers it has enough evidence to prosecute, and other considerations, including:

the seriousness of the alleged offence;
whether fraudulent intent can be proven;
the extent of the efforts to perpetrate the alleged offence;
the type and value of any goods involved;
the offender’s previous history;
the extent to which the offender has co-operated with any investigation; and
the level of financial penalties known to have been imposed by courts for similar offences.

June 23, 2026June 23, 2026 by Mark Handley

Lithuania – sanctions enforcement statistics and €6.2m in fines for 2025

Lithuania’s Financial Crimes Investigation Service has issued a summary of its work for 2025, as well as a more detailed report (see pages 45-46) that includes the following:

232 suspicious activity reports from financial institutions related to suspected breaches or circumvention of sanctions;
77 of these were reported to other competent bodies in Lithuania or in other EU member states;
45 inspections from the International Sanctions Implementation Commission;
€6,236,375.46m in fines for 2025 across 12 cases;
In addition:
- in 2025, 27 cases were dealt with administratively with fines in these minor cases totalling more than €32,150
- in 2024, 19 cases were dealt with administratively with fines totalling €28,000
- in 2023, 12 cases were dealt with administratively (the value of the fines is not given)

The report also notes that 1 of the cases related to public procurement, 1 to the failure to provide information, 5 to circumvention, and 20 to the use of a bank designated by the EU.

June 17, 2026June 17, 2026 by Mark Handley

UK – OFSI imposes Russian sanctions fine of £1,000,920.59

The UK’s Office of Financial Sanctions Implementation has issued a Penalty Notice against Sabre Global Technologies Limited (SGTL) imposing a fine of just over £1m against this UK entity.

SGTL continued to provide services to JSC Ural Airlines after that entity was designated in May 2022 and after the fact of the designation was communicated to SGTL by its lawyers on the same day.

Three payments were made to SGTL by JSC Ural Airlines between June and September 2022 totalling $906,576.30. These payments were blocked by SGTL’s bank.

In October 2022 SGTL self-disclosed the breaches to OFSI.

The Penalty Notice identified the following breaches:

by invoicing JSC Ural Airlines SGTL made available a financial benefit (and so “funds”) in the form of the discharge of a debt obligation by the airline;
by continuing to provide the airline with access to a product providing travel content up until 6 December 2022, SGTL was making an “economic resource” available to the airline;
by exploring alternative payment routes to avoid the UK, including the making of a “test” payment of $200 to SGTL’s US bank account, SGTL was circumventing the UK’s sanctions in breach of regulation 19.

These breaches, especially the continued offering of SGTL’s product, were assessed as having a value of £2,634,001.54.

OFSI assessed the breaches as being in the “most serious” category given the value, the duration and the efforts at circumvention. The fine was assessed at the maximum of 50% of the value, and then the company obtained a 20% discount to reflect self-disclosure.

The Penalty Notice makes several other “Notes on Compliance”:

“firms must not test, reroute, restructure, or otherwise manipulate payment pathways in order to avoid, evade, or defeat the effect of UK sanctions. Attempts to engineer alternative channels, including staging of payments through third countries, may constitute circumvention and a breach in and of itself. Such conduct will be treated as aggravating and will significantly increase the seriousness of any case“;
“firms must be vigilant in identifying what may constitute an “economic resource” under UK sanctions regulations. Economic resources are assets of every kind, whether tangible or intangible, movable or immovable, which are not funds but can be used to obtain funds, goods, or services. Services that can be exchanged, directly or indirectly, for funds, goods, or services may constitute an economic resource even if they are intangible or provided digitally. In particular, firms should not assume that software, data services, or digital tools fall outside the scope of financial sanctions. A service that enables a designated person or entity to generate revenue, maintain operations, or otherwise obtain an economic advantage may amount to making an economic resource available“; and
“Although it is reasonable for a firm to take some time to assess the nature and extent of the breach, or seek legal advice, this should not delay an effective response to the breach. In practice, firms should contact OFSI early to inform us of a breach or potential breach. Where full disclosure is not possible, firms should make an early disclosure with partial information on the basis that it is still working out the facts and will make a further and full disclosure as soon as possible“.

June 12, 2026June 12, 2026 by Mark Handley

Belgium – three convicted of Russian sanctions breaches

Reuters is reporting that three individuals have today been convicted of Russian sanctions offences.

The offending involved the shipment of goods for the Russian defence sector via third countries including Hong Kong and Kazakhstan. The goods are described as “sanctioned goods, including rare earths, an explosive detector and a defence-related machine”.

The first defendant, named in the reporting as Victor Labin, was given an €80,000 fine and a five year prison sentence, with one year of that suspended.

The second defendant, reported to be Ruslan Labin, and tried in absentia was sentenced to six years in jail and an €8,000 fine.

The third defendant, named only as P.I., was given a three year sentence, suspended for five years, and an €8,000 fine.

June 10, 2026June 10, 2026 by Mark Handley

Poland – individual fined c. €4.7m for sanctioned luxury car exports to Russia

Poland’s National Tax Administration has issued a press release confirming the imposition of a PLN 20,000,000 (c. €4.7m) fine on an unnamed entrepreneur.

This is separate from another fine of the same amount that was imposed in April on a company for luxury car exports.

The entrepreneur exported 177 cars and one motorbike between January and June 2023 each valued at over €50,000 in breach of the EU’s prohibition against the export of luxury goods to Russia with a total value of over €19m.

My thanks to Dr Marcin Lukowski for pointing me to the announcement.

June 1, 2026June 1, 2026 by Mark Handley

Estonia – sanctions enforcement data since January 2026 for Customs and Tax Board

Collating the outcomes published in the weekly reports by Estonia’s Tax and Customs Board (see our earlier post for the period from 14 October 2025 to 13 January 2026), reveals the following data:

18 fines
total fines of €226,669, with most being small and one of €219,210 including confiscation
13 cases referred to misdemeanour prosecution
3 cases referred to criminal prosecution, including one case that resulted in a 1 year jail term, a 3 year ban on entry to Estonia and a €3400 fine
6 cases referred for further investigation.

The weekly reports give details of many other prevented exports and imports where no further action was taken for first time offenders.

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.