Following Russia’s invasion of Ukraine in 2022, there has been an unprecedented array of sanctions and asset-freezing measures targeting Russia and those supporting its war effort.
In the years that followed, policymakers focused on expanding sanctions programmes and establishing the legal and institutional frameworks necessary to support enforcement. That focus is now shifting.
Historically Europe and the UK have been slow to enforce sanctions violations. We are now seeing an unprecedented shift towards aggressive enforcement. Below we highlight recent enforcement and policy actions and trends across Europe and the UK and practical considerations.
Recent Enforcement and Policy Actions
The EU has been moving towards a harmonised position with respect to sanctions enforcement and penalty standards through Directive (EU) 2024/1226, which requires member states to criminalise sanctions violations and establish minimum penalty standards. The transposition deadline passed on 20 May 2025, and the Commission has since pursued infringement proceedings against member states that failed to transpose the Directive on time.
In June 2026, the Commission sent reasoned opinions to Spain, France and Austria, and in July 2026 a further reasoned opinion was issued to Poland for failing to fully incorporate the Directive into national law.
Meanwhile, several member states have completed transposition, including Germany (which transposed through the Act on the Adjustment of Criminal Offences and Sanctions for Violations of Restrictive Measures, with proceedings closed on 4 June 2026), the Netherlands (which confirmed that existing Dutch law already satisfies the Directive’s requirements) and others such as Finland, Sweden and Italy. France has proposed a bill (Projet de loi n.2544), which was referred to the National Assembly in March 2026, but parliamentary consideration remains pending.
There has been an unprecedented uptick in sanctions enforcement action across Europe as well as the UK in 2026, we summarise a number of those enforcement actions below:
| Jurisdiction | Date | Enforcement Action | Key Details |
| Germany | February 2026 | Arrests of sanctions evasion network | Five suspects arrested in Lübeck for running a network of shell companies to supply the Russian defence industry, involving at least 16,000 deliveries to 24 listed Russian arms companies with goods valued at approximately €30 million. |
| France / Belgium | March 2026 | Joint seizure of shadow fleet tanker in North Sea | Belgian special forces, with the assistance of French helicopters, seized the oil tanker Ethera in the North Sea (Operation Blue Intruder). Vessel escorted to Zeebrugge; false documentation suspected. |
| Germany | March 2026 | Convictions for luxury car exports to Russia | Two individuals convicted for exporting 111 armoured luxury cars to Russia. Main defendant sentenced to 6 years’ imprisonment; approximately €20 million confiscated as proceeds of crime. |
| UK | March 2026 | OFSI penalty on Apple subsidiary (£390,000) | OFSI imposed a £390,000 penalty on Apple Distribution International Limited for making funds available to Okko LLC, a company owned by a designated person. First case resolved under OFSI’s new settlement scheme. |
| Germany | April 2026 | Customs raids on companies exporting machine parts and chemicals | Raids conducted on 14 premises in the Rhine-Main region targeting two companies suspected of exporting machine parts and chemical substances to Russia via foreign logistics service providers. Assets of approximately €1.135 million seized. |
| Netherlands | May 2026 | Arrests for hosting services to sanctioned Russian entities | Dutch FIOD arrested two company directors for indirectly making resources available to EU-sanctioned entities by facilitating “destabilizing activities” against the bloc, including cyberattacks, interference and the spread of misinformation. Over 800 servers seized across two data centres, along with laptops and telephones. |
| Austria | May 2026 | Arrest for procuring specialised industrial goods for the Russian arms industry | The managing director of an entity, a Belarussian national, was arrested for supplying CNC machines and specialised metalworking tools (both goods subject to trade sanctions under the EU Russia Sanctions regime) to Russia. The company used multiple international shipping companies to conceal the ultimate end user destinations of the exports. |
| UK | June 2026 | OFSI’s largest post-invasion penalty (£1 million) | OFSI fined Sabre Global Technologies Limited £1,000,920 for circumventing UK financial sanctions by providing services to Ural Airlines (designated person). First OFSI circumvention enforcement case. |
| UK | June 2026 | Compound settlements of £216,530.30 and £20,889.15 to HM Revenue and Customs | The settlements relate to unlicensed exports of military-listed goods and related activity that was in breach of the UK’s export control legislation. |
| Finland | July 2026 | Criminal conviction for illegal exports of trucks and trailers to Russia | The Finnish court sentenced an individual, Risto Riihimaki, CEO of Idän liikennevälitys IL Oy, to three years and eight months’ imprisonment for exporting 135 trucks and 29 trailers (valued at c.€17 million) to Russia in breach of EU sanctions. The company has been ordered to forfeit €6.6 million in proceeds and property value. |
| France | July 2026 | Shadow fleet tanker fined €1 million | French authorities fined the owners of the sanctioned tanker Tagor €1 million for involvement in shipping Russian oil and gas. This is the fourth shadow fleet vessel detained by France since September 2024. |
| Germany | July 2026 | Guilty pleas for industrial equipment exports to Russia | Two German businessmen plead guilty to shipping 65 consignments of engineering and industrial equipment (valued at €830,000) to Russia between 2023 and 2024, each accepting four-year custodial sentences. |
| Poland | July 2026 | EPPO investigation into sanctions circumvention | European Public Prosecutor’s Office carried out investigative measures in Katowice regarding fraudulent import of Russian birch plywood declared as originating from Kazakhstan. Estimated customs and VAT evasion of c.€253,000. |
| UK | July 2026 | Airbus Operations Limited paid a compound settlement of £6,409,388 for offences under The Export Control Order 2008 | Airbus Operations Ltd failed to keep accurate records of transfers of controlled technology as per the conditions of three of their Open General Export Licenses (OGELs); failed to keep registers and accurate records as per the OGELs; and breached a Standard Individual Export Licence on one occasion, relating to a failure of licence conditions. |
Practical Considerations
The enforcement actions summarised above, taken together with broader developments in the EU and UK sanctions landscape, point to several key trends and practical considerations for individuals, corporations and their advisers. At a fundamental level, this represents a real shift. Organisations may have historically assessed the risks of enforcement to be low, Europe and the UK’s record this year, which includes significant custodial sentences, suggests that this assessment is no longer correct.
Europe
Criminal enforcement is now a reality, not just a threat. The Finnish conviction (three years and eight months’ imprisonment for truck exports valued at c. €17 million), the German luxury car case (a six-year sentence and €20 million confiscated) and the German industrial equipment guilty pleas (four-year custodial sentences) collectively demonstrate that European authorities are now securing significant custodial sentences and substantial confiscation orders. This marks a decisive shift from the earlier phase of designation and asset-freezing towards active criminal prosecution of sanctions violations.
Germany is emerging as an enforcement leader on the continent. Germany accounts for the majority of the European enforcement actions highlighted above. The volume and severity of German enforcement activity is reinforced by the German Central Office for Sanctions Enforcement’s (Zentralstelle für Sanktionsdurchsetzung, “ZfS”) 2025 statistics report, which recorded 224 anonymous tips (a tripling compared to 2024), 183 new asset investigation proceedings opened, 189 investigations still open at year-end and eight seizures carried out (including account freezes). The ZfS also processed 15 outgoing and seven incoming international mutual assistance requests, reflecting expanding cross-border cooperation. Taken together, these figures suggest a systematic and sustained enforcement attitude that is continuing to scale. Corporations with supply chains touching Germany should take particular note.
Evasion networks and intermediary jurisdictions are the primary target. Across Europe, enforcement authorities are looking beyond individual transactions to dismantle the infrastructure enabling sanctions circumvention. The Lübeck arrests and the Rhine-Main raids targeting exports of machine parts and chemicals via intermediary countries illustrate that authorities are pursuing the networks, logistics providers and intermediaries that facilitate evasion, not merely the end-point transactions.
Maritime enforcement is a new front. France’s repeated detention and fining of shadow fleet tankers (the Tagor being the fourth such vessel detained since September 2024) and the Franco-Belgian joint seizure of the Ethera in the North Sea (Operation Blue Intruder) represent a shift from administrative sanctions listings to direct maritime interdiction using military assets. This signals a willingness by European states to deploy naval capabilities in support of economic enforcement, making European waters an increasingly hostile environment for vessels involved in sanctions-linked activity.
Enforcement is expanding beyond physical goods to digital infrastructure. The Dutch arrests for providing hosting services to EU-sanctioned entities, with over 800 servers seized across two data centres, demonstrate that the concept of “economic resources” in sanctions law is being applied to digital infrastructure and cyber-enabling services. Technology companies, cloud providers and data centre operators should assess whether their services could inadvertently be made available to sanctioned persons or entities.
The United Kingdom
OFSI is increasingly focused on enforcement. The £1 million fine on Sabre Global Technologies Limited is OFSI’s largest penalty since Russia’s 2022 invasion and, significantly, its first circumvention enforcement case. This signals that OFSI is now willing to pursue both inadvertent breaches and deliberate attempts to route around sanctions restrictions. OFSI’s 2026–2029 strategy and the UK Government’s cross-government enforcement policy paper reinforce that this is a sustained shift, not an isolated action.
Systems and controls failures remain the primary compliance risk. Both the Sabre Global and Apple subsidiary enforcement actions involved failures in sanctions screening and compliance oversight. In Sabre Global, OFSI found a lack of effective senior oversight and an inability to properly assess sanctions risks. In the Apple subsidiary case, the breach arose from a failure to identify that a newly designated entity wholly owned the intended transferee. Under the UK’s strict liability civil regime (in effect since June 2022), lack of intent or knowledge does not provide a defence. These cases underscore the importance of robust, regularly tested sanctions screening systems and adequately resourced compliance functions.
The settlement scheme is reshaping enforcement dynamics. The Apple subsidiary penalty was the first case resolved under OFSI’s new settlement scheme, introduced in February 2026, which offers a 20 percent discount in exchange for a waiver of ministerial review and appeal rights. Combined with the Early Account Scheme (up to 20 percent discount) and the revised Voluntary Disclosure and Co-operation discount (up to 30 percent), the new framework allows cumulative discounts of up to 70 percent off baseline penalties. This mechanism is likely to accelerate case resolution and increase the volume of published enforcement outcomes, while giving corporations a strong incentive to self-report and cooperate.
Extraterritorial reach is expanding. The Apple subsidiary case is notable because OFSI asserted jurisdiction over a non-UK, Irish-incorporated entity on the basis that a UK bank account was used to process the relevant payments. This approach echoes the US “causation” principle under OFAC, whereby non-US persons can face enforcement for causing a US person to breach sanctions. Non-UK corporations that use UK clearing services, maintain UK bank accounts or otherwise touch the UK financial system should be aware that they may fall within OFSI’s enforcement reach.
Cross-cutting Themes
The shift from designation to enforcement is real and accelerating. In previous years, enforcement action was sparse. 2026 has seen a marked acceleration in criminal prosecutions, civil penalties, asset seizures and maritime interdictions. Corporations should expect this trajectory to continue and should treat sanctions compliance as a board-level priority.
Beneficial ownership and concealment are the common thread. Whether through shell companies in Germany, digital infrastructure in the Netherlands, shadow fleet vessels in France, or complex corporate ownership structures in the UK, the enforcement actions highlighted above share a common focus: the identification and dismantling of concealment mechanisms used to obscure Russian nexus. Corporations should ensure that their beneficial ownership due diligence processes are sufficient to look beyond formal legal structures and identify the ultimate beneficiaries of transactions and business relationships.
Confiscation and financial penalties are increasing in scale. The quantum of penalties and confiscation orders is rising across jurisdictions — €20 million confiscated in the German luxury car case, €6.6 million forfeited in Finland and £1 million imposed in the UK’s Sabre Global Technologies Limited case. These figures signal that authorities are seeking to make enforcement economically meaningful and to ensure that sanctions violations do not pay. As OFSI moves to double its statutory maximum penalty (from £1 million or 50 percent of breach value to £2 million or 100 percent of breach value, subject to parliamentary approval), the financial consequences of non-compliance will only increase.
For tailored guidance on how these developments and actions may impact your operations, contact Bracewell’s government enforcement and investigations team.