Estonia – Tax and Customs Board sanctions enforcement statistics

As of 14 October 2025, the Tax and Customs Board of Estonia has started to publish weekly summaries of its activity, including the enforcement of sanctions at the various customs points with Russia.

Based on these weekly summaries the identification of a sanctions breach by customs officials results in one of four outcomes: 1) the import/export is prevented without further actins being taken; 2) an investigation is commenced; 3) a criminal proceeding for a misdemeanour offence is started; or 4) an on-the-spot fine is issued.

Based on the weekly reports since mid October, the following enforcement actions in categories 1-3 can be identified:

  • 3 investigations started;
  • 10 criminal prosecutions for misdemeanour offences started;
  • 14 on-the-spot fines, imposed, with values of €120, €304, €600, €1600, €1600, €800, €80, €240, €800, €600, €800, €400, €800 and €2000 (total of €10,744).

The offending is dominated by the small-scale carriage of luxury goods and euro notes.

The weekly summaries that include sanctions enforcement can be found here:

In addition, back on 18 August 2025, the Tax and and Customs Board published a half-yearly sanctions enforcement update – not previously reflected here.

This identified the following enforcement statistics:

  • 585,000 identified border crossings
  • 4,300 sanctions violations detected (said to be down 1,000 from the previous year)
  • on-the-spot fines of c. €93,000 imposed
  • 413 misdemeanour proceedings initiated
  • 19 more serious criminal proceedings initiated

Luxembourg – CSSF fines bank €185,000 including for sanctions compliance failings

Luxembourg’s financial services regulator, the CSSF, has issued a fine against Rakuten Bank SA for various compliance failings including sanctions and AML.

One of the failings identified was “accumulated significant and recurring delays in processing alerts relating to customer screening against list of persons subject to restrictive measures in financial matters”. The Notice identified a particular example of a customer subject to anti-terrorism sanctions where the review of the alert took more than six months.

Another failing identified was a failure to “apply ‘without delay’ potential restrictive measures in financial matters”.

Germany – €10 million payment to settle sanctions investigation into Usmanov

Prosecutors in Germany have settled their investigation and prosecution of Alisher Usmanov for suspected breaches of EU sanctions.

The settlement involves a payment of €10 million but no admission of liability.

The investigation related to allegations of payments made by or on behalf Usmanov, a designated person, in relation the provision of security for two properties in Germany.

United Kingdom – Gambling Commission fine of £825,000 including for sanctions screening failures

The UK’s Gambling Commission has fined Done Brothers (Cash Betting) Limited, trading as Betfred £825,000.

While much of the fine relates to player welfare and AML issues, it is being reported that part of the fine relates to the lack of an “effective policy for identifying and handling customers who might be subject to financial sanctions”.

This is not the first fine by the Gambling Commission related to sanctions compliance, as two other operators were fined in April 2024.

Estonia – four criminal convictions for Russian sanctions offences

The website containing published judgments from the Estonian courts has published a number of judgments relating to convictions for sanctions offences.

1. Conviction of Adilov Mubariz on 23 July 2025

      Decision: https://www.riigiteataja.ee/kohtulahendid/detailid.html?id=413740161

      This individual was convicted of importing a few hundred Russian cigarettes into Estonia in breach of Article 3(i)(1) of EU Regulation 833/2014. This was a second offence.

      The man was given a 3-month jail term, suspended for a 12-month probation period, and ordered to pay €798.42.

      2. Conviction of Alus Grupp OÜ and Taras Potapov on 18 September 2025

      Decision: https://www.riigiteataja.ee/kohtulahendid/detailid.html?id=419399125

      Mr Popatov was convicted of aiding and abetting the provision of a service related to a prohibited strategic good, namely resonance testing machines used in the aviation and aerospace industries. These are dual use goods

      The company Alus Grupp is a freight forwarder and Mr Popatov was one of its directors.

      Another Estonian company and its director purchased the equipment from a supplier in Switzerland and sold them to Russian customers. The invoices showed that the intended ultimate customer was a Russian company. Alus Grupp and its director, being aware of the ultimate customer, on multiple occasions transported the goods to Kazakhstan. On other occasions an intermediary based in the UAE was inserted.

      Mr Popatov was convicted. At the time of his conviction he had already served 5 months in jail. Pursuant to an agreement with the prosecution, the remainder of his 5-year sentence was suspended subject to a 5-year probation period. He was also ordered to pay a penalty of €2,215.

      The company was also convicted and given a fine of €100,000 with a further €200,000 suspended for a 5-year probation period.

      The judgment gives a detailed account of the exporting arrangements. It appears that other prosecutions of the actual exporting parties are ongoing.

      3. Conviction of Anna Shmeljova on 14 October 2025

      Decision: https://www.riigiteataja.ee/kohtulahendid/detailid.html?id=422536761

      Ms Shmeljova was convicted of multiple offences including exporting luxury goods to Russia, namely clothing and hockey skates, and importing cigarettes.

      She was ordered to pay €2,215, and given a five-month jail sentence suspended for a one year probation period.

      4. Conviction of Marine Technics Baltia OÜ and Daniil Haitin on 5 November 2025

      Decision: https://www.riigiteataja.ee/kohtulahendid/detailid.html?id=424933869

      Mr Haitin was convicted of four offences and sentenced to 4 years and eleven months in jail. This sentence was suspended for a 5 year probation period. He was ordered to pay €2,215.

      The company Marine Technics was convicted of two offences and ordered to pay €160,000, as well as €13,251.65.

      The offences related to exports of gas generators, alternators, propulsion systems, thermal cameras and other equipment to Russia, including to military end-users such as Kalashnikov Concern, and the Russian Ministry of Defence.

      False end-user certificates were prepared showing purported customers in Turkey.

      The offending had taken place between 2017 and 2019.

      The judgment notes that the court had prevented the merger or winding up of Marine Technics Baltia OÜ for the duration of the investigation in order to be able to secure a conviction and penalty.

      The judgment gives a detailed account of the exporting arrangements.

      Latvia – company and individual convicted for organizing tour groups to Crimea

      Latvia’s FIU has announced the successful appeal of an earlier acquittal resulting in the conviction of an individual and company for providing services related to the tourism sector in Crimea – i.e. organizing tourist trips to Crimea.

      The case remains subject to further appeal.

      The company was fined €10,500 and the individual sentenced to 100 hours of community service.

      Finland – €540,000 fine for sanctions compliance failings by online retailer

      The Regional State Administrative Agency for Southern Finland has issued a €540,000 fine to online retailer Verkkokauppa.com for failings under the Anti-Money Laundering Act. As one of the compliance requirements under the act is compliance with EU and UN sanctions, some of the compliance failings identified included a lack of sanctions screening for customers, including high risk customers seeking to pay cash.

      The full Decision is here.

      My thanks to Aleksi Pursiainen for mentioning this case on the most recent monthly sanctions webinar hosted by the Network for Financial Crime Prevention.

      Latvia – 247 administrative penalties for Russian trade sanctions breaches since June

      At a conference held last week in Riga, the Director of Latvia’s Customs Board, gave figures on the number of penalties imposed under new rules introduced on 10 June 2025 allowing administrative penalties for import/export breaches of Russian sanctions where the value of the goods was less than €10,000.

      Under those rules, in addition to confiscation of the goods in question, the minimum fine for a company is €10,000 and a maximum of €30,000. For individuals the maximum fine is €10,000.

      At the conference (video is here, with the figure given at 3:15), it was stated that Latvia had imposed 247 such penalties to date, although some of those are the subject of appeals.

      Germany – 16 years of jail and €30m confiscated for nearly 500 luxury car exports to Russia

      This story is actually from September 2024, and was previously missed by this blog.

      Three individuals were convicted of 430 separate violations of the German Foreign Trade Act by way of exports of nearly 500 luxury cars to Russia in breach of sanctions.

      The individuals falsely declared the exports were for Belarus.

      Two of the individuals were each sentenced to 6 years in jail, and the third to 4 years.

      In addition €30m in the gross proceeds of the sales were confiscated.

      © 2009- Duane Morris LLP. Duane Morris is a registered service mark of Duane Morris LLP.

      The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

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