European Sanctions Enforcement – Round Up Of A Busy Summer

It has been a busy summer on the enforcement front but the blur of repeated individual announcements can, ironically, mask the scale, breadth and scope of the current level of enforcement activity taking place across Europe.

So to help we have put all the posts since June into one place.

Collectively these paint a picture of enforcement in 19 different countries (20 if you want to count Guernsey separately). Of these 16 are EU member states with enforcement also seen in the UK, Switzerland and Iceland.

There have been 7 criminal convictions generating 19.5 years of jail time, and fines and confiscations of over €9m , as well as multiple raids of companies and homes (in Bulgaria, Denmark, Estonia, Germany, Italy, Latvia, Lithuania, the Netherlands, Portugal and Spain), not to mention the announcement of multiple arrests and investigations. And this is just what is public.

For those who remember what enforcement used to look like before 2022, activity like this is fairly extraordinary.

Bulgaria

• 23 August: raids in conjunction with Lithuanian and Portuguese authorities on exporter
• 13 August: raids on alleged arms exporter to Russia
• 4 August: raids in conjunction with German authorities on machine tool manufacturer

Czechia

• 30 June: investigations launched into 12 companies suspected of sanctioned exports

Denmark

• 23 July: raids on paint manufacturing company and company and management charged

Estonia

• 27 August: sentence of 3 years for various offences including attempted export of luxury goods
• 19 August: prosecution commenced of lawyer suspected of taking payment from and providing services to designated person
• 13 August: Russian diplomat expelled and other convicted for sanctions violations
• 4 August: enforcement statistics update re sanctioned timber with 23 violations identified
• 22 July: sentence of 6.5 years imposed and €90,000 confiscated re luxury exports
• 11 June: investigations into suspected use of funds by designated person
• 11 June: 2 year sentence for making economic resources available to a designated person

Finland

• 10 July: investigation launched into alleged exports of ball bearings and other goods
• 30 June: Customs investigation into alleged electronics exports to Russia

France

• 1 July: ACPR imposes fine of €600,000 for sanctions compliance failings

Germany

• 4 August: raids in conjunction with Bulgarian authorities on machine tool manufacturer
• 15 July: 5 year sentence and €5m confiscated for car exports
• 10 July: raids conducted in relation to alleged import of sanctioned caviar
• 4 July: raids and three arrests as part of investigation into alleged exports of luxury cars
• 3 June: reporting that 41 criminal prosecutions brought in relation to export of luxury cars to Russia

Greece

• 15 July: investigation made public into alleged imports of sanctioned timber

Guernsey

• 4 August: licence revoked and fines of £210,000 imposed on financial services firm and individual

Iceland

• 13 August: first fine (c. €153,000) on a bank for sanctions compliance failings

Italy

• 30 June: Italian police raid premises related to Iran's military support for Russia

Latvia

• 27 August: multiple investigations into suspected imports of urea from Belarus
• 3 July: announcement of 91 confiscation proceedings re criminal property from sanctions violations
• 3 June: announcement revealing 61 new sanctions prosecutions brought in 2025

Lithuania

• 23 August: raids and arrests in conjunction with Bulgarian and Portuguese authorities on exporter
• 11 June: investigations into suspected use of funds by designated person

Malta

• 8 July: two fines for sanctions violations made public

Netherlands

• 13 August: professional football team barred from leaguesdue to risk that it is owned or controlled by a designated person
• 10 July: person sentenced to 3 years in jail for sharing technology
• 10 July: confiscation of €1,013,956.00 as profits from provision of prohibited services
• 4 July: raids and arrests for company alleged to be supplier to the shadow fleet
• 11 June: DNB issues instruction to trust offence for sanctions compliance failings

Portugal

• 23 August: raids in conjunction with Bulgarian and Lithuanian authorities on exporter
• 18 June: three court judgments reveal ongoing sanctions investigations

Spain

• 15 July: investigation launched into alleged imports of sanctioned timber
• 2 July: investigation into alleged import of sanctioned diesel and fuel
• 18 June: investigation into alleged exports of machinery to Russia

Sweden

• 11 June: investigations into suspected use of funds by designated person

Switzerland

• 25 August: publication of 13 Administrative Penalties for sanctions offences

United Kingdom

• 13 August: suspended sentence for designated person convicted of refusing the provide financial information
• 4 August: OFSI imposes £300,000 fine for transfer request on behalf of designated person
• 8 July: HMRC imposes fine of £1,160,725 for prohibited exports to Russia
• 1 July: individual charged with making funds available to designated persons
• 30 June: prosecution of two individuals suspected of arms exports to Iran, Libya, South Sudan, Sudan and Syria
• 30 June: conviction of designated person for failure to provide financial information
• 25 June: Solicitors Regulation Authority fined law firm £600 for sanctions compliance failings

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.