Trade Sanctions – European Sanctions Enforcement

March 17, 2025 by Mark Handley

Germany – prosecution to proceed against individuals alleged to have exported machinery to Crimea

It is being reported that the Hamburg regional court has ordered that trial should proceed against two of the five individuals who being investigated for alleged exports of machinery to Crimea in breach of the EU’s sanctions.

As per our earlier posts (from 2024 and 2021 and 2018), the investigation relates to power generating turbines exported from Germany. Last year five individuals were charged.

The trial will now proceed against two of these with the court ruling that there was insufficient evidence against the other three. The prosecutor’s office has appealed the decision in relation to the other three.

March 13, 2025March 13, 2025 by Mark Handley

Germany – raids and arrests for suspected luxury car exports to Russia

It is being reported (here and here) that authorities in Berlin and Bavaria have conducted raids on five premises and arrested three individuals for the suspected export of nearly 200 luxury cars to Russia in breach of the EU’s sanctions.

The value of the cars is reported to be approximately €21 million, and they were exported via third countries such as Belarus, Uzbekistan and Tajikistan.

March 13, 2025March 13, 2025 by Mark Handley

Latvia – prosecutions brought against four for exports to Russia

It is being reported that Latvia’s State Security Service has referred four individuals for prosecution for alleged exports of satellite communications equipment for the Russian military in breach of EU sanctions and other Latvian laws.

The investigation is ongoing and it is reported that other individuals are suspected of being involved.

The goods exported were Starlink Mini satellite communication systems.

March 5, 2025 by Mark Handley

Estonia – 8 sanctions convictions and more than 100 active criminal cases

The Yearbook of the Prosecutor’s Office in Estonia has published details on its enforcement of sanctions to date.

I thank Siiri Grabbi of the Coop Pank in Tallinn for the reference.

The Yearbook states that eight criminal convictions have been obtained with one also appealed. It does not provide details of the offending or the sentences imposed.

The Yearbook further notes that the Prosecutor’s office currently has more than 100 active criminal cases.

February 28, 2025 by Mark Handley

Poland – 275 ongoing sanctions investigations

It is being reported that the Polish authorities have responded to a press request by confirming that they have 275 sanctions investigations that are ongoing.

No further information was provided on these investigations. It is unclear how many of these relate to Russian sanctions.

February 28, 2025February 28, 2025 by Mark Handley

United Kingdom – HMRC has opened 65 trade sanctions investigations since 2022

In a letter written from the UK’s HMRC (the body with primary responsibility for the criminal enforcement of trade sanctions) to Parliament’s Treasury Select Committee, HMRC has provided significant information on its recent enforcement efforts.

Year	Number of investigations opened
2021	0
2022	14 (all relating to Russian sanctions)
2023	22 (20 relating to Russian sanctions)
2024	29 (27 relating to Russian sanctions)

Of those 65 investigations, HMRC has confirmed that 30 remain live of which 27 relate to Russian sanctions.

The letter tabulates the six fines imposed to date for breaches of the Russian sanctions, and in relation to the largest single fine of £1,000,000 imposed in August 2023 (see our earlier post), the letter notes that this fine relates to “brokering and technical assistance” and not to an actual export.

HMRC’s letter also states that a previously published compound penalty of £1,000 from September 2023 (see our earlier post) was actually for a breach of the UK’s Iran sanctions despite being described at the time as “relating to the attempted export of Dual Use goods”.

HMRC’s letter also states that in October 2024 it referred a case for possible prosecution to the Crown Prosecution Service.

February 28, 2025 by Mark Handley

Italy and Estonia – extradition of sanctions suspect to Estonia

It is being reported that the Estonian Prosecutor’s office has successfully completed the extradition of suspect Ivan Anchevsky, after he was arrested in Italy.

The prosecution of Anchevsky for suspected exports to Russian in breach of EU sanctions, forms part of a wider investigation including two unnamed Estonian companies and their boards of directors.

Anchesvsky, who is a citizen of both Estonia and Russia, is suspected of using his companies Melytec and Melytec Testing to export sanctions goods to Russia.

February 24, 2025February 24, 2025 by Mark Handley

Netherlands – updated Russian sanctions enforcement statistics

Updated enforcement statistics are being reported (here behind a paywall, and here in summary) for the Dutch Fiscal Intelligence and Investigation Service (FIOD) and from Dutch Customs.

FIOD is reported to have conducted 30 cases in the three years since February 2022, with six resulting in convictions, and twenty investigations ongoing.

Customs are reported to have started 80 cases, with 16 ongoing, and 64 settled with fines of between €500 and €200,000.

February 20, 2025February 20, 2025 by Mark Handley

Sanctions enforcement in 2024: Europe vs the US

In 2024, probably for the first time ever, Europe (meaning the EU, UK, Switzerland and Norway), imposed and obtained a greater number of fines and convictions; a higher total value of fines; and also a higher single largest fine, for sanctions breaches than those imposed by the authorities in the United States.

The US figures combine the enforcement actions taken by OFAC and BIS, as well as criminal convictions secured by the DOJ.

The European figures are taken from this blog.

The US obtained 52 successfully-concluded enforcement actions, while Europe secured 118.

The US (OFAC and BIS combined) imposed fines equivalent to €56.8m, while Europe imposed a total of €88.5m.

The single largest US fine was $20m in relation to Iran sanctions. The largest fine in Europe was the UK’s £29m imposed on Starling Bank.

February 17, 2025February 17, 2025 by Mark Handley

Ireland – charges of Russian sanctions breaches not pursued following Gardaí investigations

Ireland’s Gardaí (National Police) have confirmed to Global Investigations Review that it has referred two investigations for prosecution for alleged breaches of the EU’s sanctions imposed on Russian in the wake of the full-scale invasion of Ukraine in 2022.

It was also confirmed that the Public Prosecution Service declined to being charges in both investigations.

One such referral to the DPP was reported to have taken place in April 2023.

In March 2024 it was reported that the Gardaí had four investigations ongoing into suspected Russian sanctions breaches, but the status of those further investigations is unknown.