Trade Sanctions – Page 10 – European Sanctions Enforcement

September 30, 2025September 30, 2025 by Mark Handley

Finland – 26 investigations into breaches of trade sanctions started in 2025

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:

Petty regulation offences are punishable only by fines;
Regulation offences are punishable by fine or imprisonment for a maximum of 2 years; and
Aggravated regulation offences are punishable by imprisonment of at least 4 months and not more than 4 years.

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

September 30, 2025September 30, 2025 by Mark Handley

Italy – stock exchange regulator investigates luxury goods manufacturer

It has been reported (here, behind a paywall), that CONSOB (the Italian stock exchange regulator) has been investigating comments made by luxury goods manufacturer Brunello Cucinelli in relation to the company’s compliance with the EU’s Russian sanctions.

Last week several short sellers of Brunello Cucinelli stock issued reports alleging that the company’s stores remained open in Russia and continued to sell prohibited luxury goods. Despite denials from the company, these reports led to a sharp reduction in the price of the shares and trading in the stock was suspended.

The CONSOB investigation is primarily focussed on the question of whether the company has misled the market in its public comments and denials.

September 24, 2025September 24, 2025 by Mark Handley

Poland – 20 people detained for alleged luxury car exports to Russia and Belarus

Poland’s Central Bureau of Investigation of the Police has issued a press release relating to the arrest of 20 people for alleged involvement in a scheme to export of approximately 600 luxury cars to Russia and Belarus in breach of the EU’s sanctions.

The scheme is said to have involved a sequence of sales within the EU, followed by sales to customers in third countries such as Kazakhstan and Azerbaijan, followed by a further transfer to Belarusia or Russia.

Several of the defendants are being detained in custody while the investigation continues.

More than PLN 10m in bank accounts have been frozen as part of the investigation.

September 22, 2025September 22, 2025 by Mark Handley

Poland – updated statistics on the 42 imposed sanctions fines

With grateful thanks to the Ministry of Finance and the Economy in Poland for the provision of the information, this blog can provide an up-to-date summary of the scale of financial penalties imposed by the Polish authorities in relation to Russian and Belarusian sanctions violations.

These figures relate to the period up to 28 August 2025.

In total the Polish authorities have imposed 42 financial penalties, broken down on the following basis:

24 penalties in relation to breaches of EU Regulation 833/2014, with total fines of PLN 6,850,949 (just over €1.6m);
6 penalties for breaches of EU Regulation 269/2014, with total fines of PLN 911,515 (just over €213,000);
10 penalties for breaches of the Polish Sanctions Act of 13 April 2022, with total fines of PLN 18,886,441 (€4.42m);
1 penalty under EU regulation 765/2006 in relation to Belarus, with a fine of PLN 7,367 (€1,727); and
1 penalty relating to both Regulations 833/2014 and 765/2006, with a fine of PLN 36,272 (€8,506).

This updates the statistics previously published on this blog from July 2024.

It shows that Poland has imposed a 18 fines since that time. Of those 12 were under Regulation 833/2014, four were under Regulation 269/2014, and the two smaller fines relating to Belarus have also been imposed since July 2024.

September 18, 2025September 18, 2025 by Mark Handley

Switzerland – raids on gold trading company re Russian sanctions breaches

On 12 September 2025 Switzerland’s SECO conducted raids on the Zug offices of Open Mineral AG.

This was part of an investigation into suspected breaches of Switzerland’s sanctions against gold trading from 2022, and specifically purchases of Russian gold done through a UAE subsidiary.

The company has stated that its trades were done in accordance with applicable laws and that it is cooperating with the authorities.

September 18, 2025September 18, 2025 by Mark Handley

Denmark – charges for alleged military exports to Russia

It is being reported that the Danish authorities have charged a company and two senior executives with suspected exports of components for military goods to Russia.

The investigation is reported to have started in 2023 and included raids in December of that year. The investigators also obtained permission to obtain phone taps on the phones of the two executives.

The exports are alleged to have been shipped via China.

September 16, 2025 by Mark Handley

Germany – prosecution seeks 5 year jail term for sanctions violation ringleader

It is being reported that as part of an ongoing trial in Hamburg, that the Prosecutor’s Office is seeking a jail term of 5 years and 10 months for the main defendant. It is noteworthy that the Defence is seeking a jail term of 3 and a half years underlining the seriousness of the offending.

The alleged offending relates to the export of approximately €800,000 in electrical components and laboratory supplies.

There are four other individual defendants with the prosecution seeking shorter jail terms of suspended sentences for those.

The trial has been ongoing since April, and the verdict is expected shortly.

September 11, 2025September 11, 2025 by Mark Handley

Germany – investigation into low-value import from Russia

It is being reported that the Schwerin Public Prosecutor’s Office has commenced an investigation into suspected imports of prohibited goods from Russia.

The case illustrates the appetite for investigating suspected sanctions breaches even of low value, as the cost of the goods imported is said to be €26.83: consisting of a bar of soap, a decorative piece of wood and a CD. The recipient is reported as saying that the goods were a gift from a long-standing Russian friend.

September 11, 2025September 18, 2025 by Mark Handley

Finland – CEO acquitted of sanctions charges

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.

September 8, 2025September 8, 2025 by Mark Handley

Netherlands – company convicted of sanctioned exports ordered liquidated

Further to our earlier post from October 2024 reporting that a company had been convicted of exporting prohibited aircraft parts to Russia and fined €165,826, a judgment published on 5 September 2025 dealt with an application to liquidate the company by the Public Prosecution Service.

The company in question has now been named as Jet Air Equipment BV.

The Gelderland Court has ordered that the company be declared prohibited and that a liquidator be appointed for the dissolution of the company. The company will have the ability to make submissions on the identity of the liquidator, but the court reserved the right to make the appointment itself.

In addition an unnamed company director has been barred for 3 years from serving as a company director.

An application to have all the assets of the company be distributed to the state was denied.

The Dutch courts have previously ordered the liquidation of a convicted company.