Trade Sanctions – Page 4 – European Sanctions Enforcement

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.

February 17, 2025February 17, 2025 by Mark Handley

Netherlands – company settles with prosecution and fined €120,000 for Crimean exports

The District Court in Amsterdam has issued a judgment arising from the export of machinery from the Netherlands to Crimea in 2016 and 2017 for use in the construction of the Kerch Bridge.

The company (a B.V. unnamed in the judgment) reached a settlement with the prosecution, whereby no defence was advanced, no appeal would be lodged, and the company agreed to pay the fine of €120,000.

The court found that the prosecution case was made out, and confirmed the terms of the settlement and the proposed fine.

The judgment does not mention any confiscation of the proceeds of crime.

Judgments have also been released in relation to the related prosecutions of two individuals (here and here), both of whom were acquitted.

February 17, 2025 by Mark Handley

Netherlands – company and director suspected of exporting computing equipment to Russia

The Dutch FIOD has issued a press release stating that a 57-year old man has been arrested and that the individual and a company are suspected of exporting US$24 million in computer motherboards and graphics cards to Russian customers in breach of the EU’s sanctions against Russia.

Residential and commercial premises were raided, and bank accounts seized.

The exports are alleged to have been done through Hong Kong, the United Arab Emirates and Cyprus

February 17, 2025February 17, 2025 by Mark Handley

Spain – five arrested for suspected chemical exports to Russia

The Spanish authorities have issued a press release confirming a series of raids in the provinces of Barcelona and Valencia and the arrest of five people.

The raids and arrests are said to be the second phase of Operation Probirka, the first phase of which was conducted in October 2024 (see our previous post).

The bodies involved were the National Police and the Tax Agency.

The allegations include the use of front companies and dummy intermediaries in Kyrgyzstan and Armenia, and the export of chemicals which can be used in the manufacture of explosives and chemical weapons.

February 6, 2025February 6, 2025 by Mark Handley

Lithuania – sanctions raids, arrests and seizures related to trucking companies

It is being reported that the Lithuanian Customs Criminal Service has conducted raids at multiple addresses in Vilnius and Rudamina, has arrested four individuals (2 Belarus nationals and 2 Lithuanian nationals), and seized 33 vehicles valued at €1.5 million.

The vehicles are 17 trucks, 15 semi-trailers and a mini-bus, which are said to have been involved in alleged trade with Russia and Belarus in breach of the EU’s sanctions.

The first round of raids were conducted on 29 January with further raids since then.

January 28, 2025January 28, 2025 by Mark Handley

Estonia – 83 criminal prosecutions for Russian trade sanctions violations since 2024

It has been reported that during 2024 Estonia’s Internal Security Service commenced 71 criminal cases in relation to suspected trade with Russia in breach of the EU’s sanctions, and has commenced another 12 already during 2025. These cases are said to be for the more serious, intentional or repeat offenders.

The same report note that Estonia’s Police and Border Guard Board are currently identifying an average of 12 sanctions violations per day predominantly by individuals attempted to take cash or luxury goods into Russia. This is reported to be down from a previous average of 22 violations per day.

With all people crossing the border being subject to inspection, first time offenders are required to either turn back and not cross, or to accept confiscation of the goods/items and continue the journey.

January 23, 2025 by Mark Handley

Germany – raids and arrests of suspected exporters of luxury cars to Russia and Belarus

It is being reported that on 16 January raids were carried out at six addressed in Ludwigshafen, Schifferstadt and Mannheim and a 53-year old was arrested on suspicion of exporting over 150 luxury cars to Russia and Belarus valued at more than €7,500,000.

Cash and cars valued at more than €500,000 were seized and accounts frozen.

The same article reports on another case from November 2024 (also reported here), in which a 26-year old was arrested and detained on suspicion of exporting 30 luxury cars to Russia valued at around €3,500,000.

January 22, 2025January 22, 2025 by Mark Handley

Finland – updated statistics on its 909 Russian trade sanctions investigations

As an update to our previous post on the 900 or so sanctions investigations started by Finnish Customs since the start of 2022, we can provide a more detailed breakdown of those figures.

The blog is happy to acknowledge the information and assistance provided by Finnish Customs.

To explain the figures below, under Finnish law sanctions offences are divided into three categories:

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

Against that background, Finnish Customs has provided a break down over time of when it commenced its many investigations and the category of offending that was being investigated.

Year	Petty Regulation Offence	Regulation Offence	Aggravated Regulation Offence	Total
2022	104	158	44	306
2023	354	86	64	504
2024	5	59	35	99
Total	463	303	143	909

The drop off in investigations relating to petty regulation offences in 2024 is to be attributed to the closure of all crossings along the land border with Russia, as most of the examples in that category had been attempts to export prohibited goods by individuals in cars and other vehicles.

January 22, 2025 by Mark Handley

Lithuania – raids and 10 arrested for suspected prohibited exports to Russia

Lithuania’s State Security Department has issued a press release detailing raids and arrests carried out on 14 January of this year involving ten suspects.

The investigation was said to have been a collaborative effort also involving Estonia and Latvia.

The principal suspect is a Russian national who is alleged to have orchestrated the supply of high-tech equipment manufactured in Lithuania to Russian customers related to the Russian defence and security industry. He remains in custody. The other suspects have been released subject to conditions.

A pre-trial investigation has been commenced by the Vilnius Regional Prosecutor’s Office in relation to the suspects.