Russia – European Sanctions Enforcement

December 8, 2025December 8, 2025 by Mark Handley

Latvia – prosecution for providing professional services to Russian companies

Latvia’s VDD has asked the Prosecution Office to commence a prosecution of a latvian national for providing prohibited services to companies in Russia.

As per the press release: “DD found that the Latvian citizen had entered into employment contracts with multiple companies registered in Russia, where the person held the positions of general director and director and directly gave prohibited consultations on economic activities, management and taxation”.

This prosecution is one of several recently launched in Latvia (see our earlier post) in relation to alleged breaches of the prohibitions contained in regulation 5n of 833/2014.

December 3, 2025December 3, 2025 by Mark Handley

Germany – investigation into businesses alleged to have exported €10m in luxury cars to Russia

It is being reported that the Munich Prosecutor’s Office is investigating a number of businesses suspected of exporting 50 luxury cars to Russia in breach of the EU’s sanctions.

The cars are said to be valued at €10 million, including one car fitted with armour valued at €650,000.

The report alleges that the exports were done via third countries including Kazakhstan.

December 3, 2025December 3, 2025 by Mark Handley

Netherlands – raids and arrests as part of investigation into sanctioned exports to Russia

The Dutch FIOD has issued a press release announcing raids on business and residential premises and the arrest of two individuals aged 39 and 60.

A company, and the two individuals, are suspected of exporting sanctioned goods to Russia via third countries in breach of the EU’s sanctions.

December 3, 2025December 3, 2025 by Mark Handley

Finland – two individuals charged with sanctioned export offences

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.

December 2, 2025December 2, 2025 by Mark Handley

Germany – raids and arrests as part of investigation into exports of equipment to Russia

German Customs has issued a press release relating to an ongoing investigation against five defendants. On 29 November three properties were raids in Oelde, and two individuals were arrested.

The investigation by the Essen Customs office, relates to the export since January 2023 of technical equipment and accessories, such as pumps, valves, filters to a company in Russia.

It is suspected that 53 shipments may have taken place via third countries.

The investigation has also frozen assets valued at €689,000.

December 1, 2025December 1, 2025 by Mark Handley

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.

November 28, 2025November 28, 2025 by Mark Handley

Finland – regulator’s audit findings on Nordea Bank’s sanctions compliance

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.

November 25, 2025November 25, 2025 by Mark Handley

Netherlands – trial commenced of shipbuilder for sanctioned exports to Russia

Further to our earlier post, the prosecution trial of Damen Shipping has commenced in the Netherlands.

The company has denied the allegations, which include that it falsified customs declarations to enable the export of 14 deck cranes to Russia during 2022 in breach of the EU’s sanctions.

Senior management have also been charged with sanctions offences.

The trial includes charges of bribery against Damen.

November 21, 2025November 21, 2025 by Mark Handley

Ireland – multiple cash seizures related to sanctions circumvention network

It is being reported that the Gardaí have conducted multiple cash seizures targetting a criminal network used for laundering money and sanctions circumvention.

The seizures value €1.36m and took place in multiple operations in Dublin and Leitrim in April and October this year.

It is alleged that the network “cleaned” the proceeds from ilegal activity and turned it into crypto currency. It is also alleged that the network provided sanctions circumvention services to the Russian state.

The Irish seizures were part of the broader Operation Destabilise which involved the UK’s National Crime Agency (see our post).

November 21, 2025 by Mark Handley

United Kingdom – National Crime Agency operation targetting sanctions circumvention network

The National Crime Agency has issued a press release relating to Operation Stabilise, which is targetted a criminal money laundering network that was also used to aid the circumvention of sanctions by Russia.

The NCA states that 45 money launderers have been arrested in the UK, and £25m seized in the UK, with international partners seizing $24m and €2.6m and arresting another 83 people.

The NCA notes the alleged involvement of networks called Smart and TGR and that a company linked to TGR’s head had purchased a 75% stake in a previously state-owned Kyrgyzstan bank – Keremet Bank – which was then used as part of the evasion/circumvention network.

The NCA reports a number of convictions for money laundering offences of individuals involved in the networks, and that the head of the Smart network is currently in custody in France.

The operation involved cooperation with the DEA, and FBI in the US, the Direction Centrale de la Police Judiciaire in France, the Jersey Police, Scottish Police, Finland’s National Bureau of Investigation, the Dutch National Police and Spanish law enforcement.