Trade Sanctions – European Sanctions Enforcement

September 9, 2026September 9, 2026 by Mark Handley

The blog’s 800th post – fines and jail terms

It was only in March that the blog passed the milestone of 700 posts, and now it is at 800. To mark the occasion we are publishing some graphs on the current state of enforcement across Europe.

Fines

The first graph shows (in blue columns) the annual values (in euros) of fines/confiscations/penalties/forfeitures for sanctions breaches across Europe from 2017 to 2026.

The green line is the number of fines in any given year valued at €1 million or more.

With nearly four months to go 2026 is at €115.3m and is on track to surpass both 2024 and 2019 in terms of total value (and 2019 had a single fine of £102m from the UK’s FCA).

What the graph also illustrates is that while 2018-2020 had a small number of very large fines, countries across Europe are now imposing a much higher number of significant fines than before.

Jail terms

The next graph is another way of showing the sea change in enforcement outcomes since 2022.

In the last three years over 175 years of jail time (not including suspended sentences) have been handed down. The adoption and implementation of the EU’s harmonization directive, is only going to reinforce and further drive this trend as more member states take on the power to impose a custodial sentence.

September 9, 2026September 9, 2026 by Mark Handley

UK – HMRC issues £7.4m penalty for supply of goods to Russia

The UK’s HM Revenue and Customs has issued its largest sanctions-related Compound Penalty to date.

The company, Illumina Cambridge Limited, was fined £7,438,840.13 for breaches of the UK’s Russian sanctions.

The published Notice gives limited information on the breaches:

“Between July 2022 and January 2023 Illumina breached regulation 25(1) through their involvement in the supply of sanctioned goods from one overseas company within their corporate group to another overseas company within their corporate group for export to Russia and other destinations“.

Regulation 25(1) prohibits the direct or indirect making available of “restricted goods” or “restricted technology” either for use in Russia, or to a person connected with Russia.

Illumina Cambridge Limited voluntarily disclosed the conduct to HNRC and cooperated with the investigation.

As noted by HMRC “sanctions breaches can occur when UK businesses are involved in supply chains that result in sanctioned goods being supplied indirectly to Russia (or other countries subject to trade sanctions), even when no goods have been exported from the UK“.

This is the third large fine/forfeiture handed out by UK authorities in the last few weeks following the £4.7m fine from OFSI (2 September) and the $5.2m forfeiture from the National Crime Agency (27 August).

September 4, 2026 by Mark Handley

Sweden – extradition of Russian national to the US approved to face sanctions charges

It is being reported (here, behind a paywall), the Sweden’s Supreme Court has approved an request for a Russian national to be extradited to the United States to face charges arising from the alleged export of military components to Russia via Hong Kong.

September 4, 2026September 4, 2026 by Mark Handley

Luxembourg – investigation into alleged Russian sanctions breaches discontinued

Further to our earlier post regarding a Luxembourg investigation into possible EU sanctions breaches by the company Spacety Luxembourg SA, it is now being reported that the Luxembourg authorities have discontinued the investigation.

A government spokesperson is reported to have stated that the investigation was discontinued after several mutual legal assistance requests had been made, but it is unclear whether these requests were refused, and to which countries the requests were sent.

The company was placed into liquidation in October 2025.

September 3, 2026September 3, 2026 by Mark Handley

Latvia – Customs confiscates €15m in sanctioned goods

A broadcast news story has provided data on the enforcement activity of Latvia’s Customs.

The story reports that:

roughly twice a week a shipment of sanctioned goods to Russia is stopped;
30 cargoes of military goods have been stopped; and
Customs have confiscated €15m in sanctioned goods through its work at inspections at checkpoints, of which roughly €3m has so far been sold.

The new story does not state over what period the confiscations took place.

September 1, 2026September 1, 2026 by Mark Handley

EU – further sanctioned oil tanker, the MV Sun, boarded in Mediterranean

Further to our earlier posts (here and here) regarding the tanker boardings by the EU’s operation EUNAVFOR MED Irini, it is being reported that yesterday the same EU operation has boarded the sanctioned tanker MV Sun south of Sicily.

The boarding was conducted by an Italian naval vessel on behalf of the EU operation.

The inspection was to verify and determine the flag status of the vessel, and the vessel does not appear to have been detained.

September 1, 2026September 1, 2026 by Mark Handley

Georgia – investigation into suspected sanctioned exports to Russia

The Georgian authorities have announced an investigation arising from a Azerbaijani-registered lorry attempting to cross from Turkey into Georgia in July.

The investigation arose from checks carried out at the Sarpi checkpoint. During an inspection of a lorry, the driver declared that the goods were of EU origin and were destined for Russia. The lorry was turned back.

Later the same day the lorry returned to the same checkpoint and this time the goods were accompanied by documents asserting a Turkish origin. Inspection revealed the goods to have had German and Croatian origin.

The case has been referred to the Investigation Service of Georgia’s Ministry of Finance for further action with offences of breaching sanctions and forgery the subject matter of the investigation.

September 1, 2026September 1, 2026 by Mark Handley

Netherlands – confiscation of proceeds from sanctions breaches reduced on appeal

Further to our earlier post regarding a 2024 conviction and confiscation, the Hague Court of Appeal has ruled on an appeal by the convicted defendants on the quantum of the confiscation.

The revenue from the criminal transactions was €1,924,579.20, with the first instance court allowing deductions of costs, to arrive at an initial confiscation order in the sum of €298,310. This was in line with the Dutch methodology of confiscating net profit rather than gross profit.

The defendant raised a number of arguments:

1) that there should be no confiscation;

2) that certain costs (transport, packaging, testing, etc) had been improperly not deducted from revenue;

3) that the value of confiscated goods should be credited in favour of the defendant; and

4) that the defendant did not have the financial means to satisfy the confiscation order.

All of these arguments were rejected by the Hague Court of Appeal. Despite this, the Court reduced the sum to be confiscated to €250,195. The Court provided no reasoning, or basis for, this reduction.

August 27, 2026August 27, 2026 by Mark Handley

UK – National Crime Agency agrees forfeiture of $5.2m to resolve sanctions and AML investigation

The UK’s National Crime Agency has issued a press release stating that it has entered into a settlement agreement with ENEX Premium Trading Limited, owned by Nadir Valiyev and registered in St Kitts and Nevis.

The press release states that the settlement involves no admission of criminality by either ENEX of Mr Valiyev.

The allegation that was investigated from 2024 onwards was that ENEX was involved in the shipment of stolen Ukrainian grain. The NCA obtained an Account Freezing Order in November 2024 over sums received from China between July and September 2024. It is those funds which have now been forfeited.

August 27, 2026August 27, 2026 by Mark Handley

UK – Russian-flagged vessel issued with movement direction to leave UK waters

The UK’s Department of Transport has today published information on events that took place on 27-28 January 2026.

On 27 January, the Russian-flagged, registered and operated vessel the Sinegorsk contacted HM Coastguard stating an intention to enter UK waters to undertake repairs to its hull.

The Centre for Transport Sanctions within the Department of Transport conducted an investigation into the sanctions status of the vessel.

After determining that the vessel was within the scope of the discretionary powers to issue a “movement direction”, the Secretary of State decided to issue such a direction. On 28 January HM Coastguard issued the notice to the Sinegorsk which proceeded to comply with the direction and leave UK waters.