Further to our earlier post, it is now being reported that the Finnish authorities have charged the two remaining defendants (the first having plead guilty) on suspicion of exports to Russia of dual-use drones, laptops, computer processors, smartphones and laser rangefinders in breach of the EU’s sanctions.
The value of the exports is said to have been around €140,000, with the exports said to have taken place between 2022 and 2024.
Finland’s Financial Supervisory Authority has published the results of an “audit” on Nordea Bank in relation to the bank’s compliance with the asset freeze and export prohibition aspects of the EU’s Russian sanctions.
The result of the audit was a finding of a “very significant lack of information obtained and retained by the bank”, with a lack of updating on the information that was obtained. In addition, “shortcomings of great significance” were found in relation to customer due diligence, and a lack of adequate assessment of the risk of sanctions circumvention including payments that involved “a high risk country from the perspective of sanctions evasion”.
The announcement from the FIN-FSA does not indicate whether any further regulatory action will be taken.
My thanks to Louis Vargas of the Network for Financial Crime Prevention for informing on this published audit.
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.
It is being reported, that after pleading guilty to charges of exporting dual-use goods to Russian in breach of the EU’s sanctions, a 20-year old student has been given a 14-month suspended sentence.
The student exported dual-use drones, laptops, computer processors, smartphones and laser rangefinders valued at nearly €74,000.
Further to our earlier post, two other accomplices were also arrested in May 2024 and have been investigated for exports valued at another €70,000.
As well as pleading guilty the student is said to have co-operated with the investigation. The outcome relating to the other two defendants is not yet known.
Further to our earlier post regarding Finland’s hundreds of sanctions investigations, we are pleased to acknowledge the help of Finnish Customs in supplying newly-updated information on the investigations so far commenced for breaches of the EU’s trade sanctions. These figures do not include investigations relating to financial sanctions.
While information on the penalties/sentences imposed is not available it can be noted that:
The updated figures include concluded enforcement actions up to 17 September 2025, and include some revisions to the previously supplied data for the previous years.
As previously noted the reduction in the punishment of petty regulation offences between 2023 and 2024 is most likely to be attributed to the closures of the land crossings into Russia.
| Year | Petty Regulation Offence | Regulation Offence | Aggravated Regulation Offence | Total |
| 2022 | 104 | 163 | 39 | 306 |
| 2023 | 353 | 81 | 58 | 492 |
| 2024 | 5 | 59 | 35 | 99 |
| 2025 | 2 | 15 | 9 | 26 |
| Total | 464 | 318 | 141 | 923 |
The result of a prosecution of a company’s CEO has been reported in the Finnish press.
The company received an order from a Russian customer for non-prohibited goods. The products then became sanctioned leading to a dispute as to whether the contract should be performed. The Russian customer threatened to bring a claim if there was no delivery.
The Finnish company’s CEO decided the best path was to go through some of the motions of an export, which would then be blocked, and this would be proof that delivery could not be made.
The company made an export declaration for the goods (motor switches), and it was at this point that the flaw in the plan became apparent.
Customs considered that the company was seeking to export sanctioned goods and investigated and charged the CEO with the appropriate sanctions breaches.
Luckily for the CEO the District Court of South Karelia this week has acquitted the CEO. The court relied on the fact that the company had taken no steps to move the goods from its warehouse, and the court found that there was no real intention to actually export.
I am very grateful to Aleksi Pursiainen, of Solid Plan Consulting, for drawing this case to my attention.
If ever there was a cautionary tale on the drastic consequences that can come from not having appropriate sanctions wording in your contracts, this is it.
Finland’s Customs has issued a press release announcing the an investigation into a company in the Helsinki region that is suspected or arranging exports of goods to Russia via third countries including Lithuania, Bulgaria, Poland, Belarus, Kazakhstan and Kyrgyzstan.
The exports are suspected of ranging from 2022 to 2025, and to have included direct sales by the company.
The goods involved are ball bearings and industrial motors with an estimated value of €300,000.
The investigation appears to have been started with the interception of a consignment of prohibited dual-use goods which was being directly exported from Finland to Russia.
On Thursday Finland’s Customs announced details of an ongoing investigation into a suspected aggravated offence of breaching the EU’s sanctions. This is the most serious category of offence under Finnish law.
Customs are investigating a company from eastern Finland alleged to have sold electronic parts and components (semiconductors, microchips, processors and connectors) to Russia valued at approximately €2.7m.
The two main suspects are a father and son, with the son currently serving in the Russian army.
The products are alleged to have been shipped via several different routes including via other EU countries, Hong Kong, direct to Russia, and others seemingly collected in Finland.
A tax investigation is also under way.
Prior to 2022 the company’s business is said to have been dedicated to tourism and the sale of art.
Finland’s Customs have issued a press release making public an investigation into the suspected export of technical documents from a nuclear power plant construction project to Russia.
The unnamed manging director of the company responsible for the construction project is identified as the person suspected of the offence.
The press release notes that the investigation is coming to an end and that, as yet, no decision on charging the individual has been made.
Finland’s Financial Supervisory Authority has published the results of an “audit” on S-Bank PLC’s compliance with the EU’s Russian sanctions.
The audit revealed a “very significant lack” of effective controls in terms of the deposit limits imposed by the EU’s sanctions. Also highlighted was a lack of training and a lack of “sufficiently effective procedures” for sanctions compliance.
The audit also noted that there was a lack of independent supervision of business units with risk control sitting within each unit and being involved in the initial business decisions and so were unable to provide an independent check on those decisions.
Overall the audit findings were described as being of “high significance”, but it is unclear what further regulatory action might be taken.
