Europe Tightens Its Sanctions Enforcement, with Heightened Penalties and a Wave of Export Cases

Since 2022, sanctions have been Europe’s primary tool to pressure Russia to end its war in Ukraine—and concerns since then have lingered about their effectiveness, amid uneven enforcement.

But both the European Union and the United Kingdom have been shifting of late toward more aggressive and systematic scrutiny of sanctions violations, a Kharon review of government actions, court proceedings and news reports found.

One major driver of this shift is a combination of new legal powers, expanded EU-level restrictions, and the arrival of an implementation deadline for EU member states to criminalize sanctions evasion and violations under the 2024 Sanctions Directive.

Together with Europe’s ever-expanding sanctions targets, these elements have given Russia sanctions new teeth, creating a tougher (and higher-risk) compliance environment for companies and individuals across Europe.

The EU’s new enforcement framework

Throughout 2025, the European Commission has adopted four additional sanctions packages targeting Russia, expanding listings across individuals, entities, and vessels and strengthening member states’ ability to intervene in trade flows. Notably, national authorities can now block or scrutinize exports they suspect may be diverted to Russia, even when these are routed through third countries.

May 2025 also marked the deadline for member states to transpose an EU Sanctions Directive harmonizing the enforcement framework across the 27 EU countries, which has traditionally been fragmented. The directive mandates both civil and criminal penalties for breaches of certain EU sanctions, raising the potential maximum penalties that countries must implement.

• Companies can face fines of 5% or more of their global annual turnover for serious violations.
• Individuals may face imprisonment of five years or more, depending on the severity of the offense.

Several jurisdictions have reported figures that indicate upward trends in investigations, penalties and criminal cases.

• Latvia’s Customs Board director, for instance, announced in June that the country had imposed 247 administrative penalties for Russian trade sanctions violations. In September, its Financial Intelligence Unit announced that it was involved in more than 600 ongoing criminal investigations into more such breaches.
• Since Russia’s full-scale 2022 invasion of Ukraine, authorities in Denmark have now charged at least 11 companies and seven individuals with violating sanctions.
• And as of August, Polish authorities had issued 42 financial penalties linked to violations of sanctions on Russia and Belarus since the start of the war.

In Focus: Evasion of Export Controls

A common pattern of sanctions violations that EU states have targeted is the export of controlled or banned goods to Russia by routing them through intermediary countries, to avoid detection.

Several examples across Europe this year illustrate how these schemes—and countries’ enforcement in response—work.

Luxury Vehicles and High-Value Goods

A German court in July sentenced a 56-year-old businessman to five years in prison for arranging the export of 71 high-value vehicles to Russia. According to prosecutors, the shipments were routed through third countries to disguise their final destination. Beyond the conviction, authorities seized approximately €5 million in criminal proceeds, along with three luxury cars.

The case followed another out of Germany last year, in which three men received prison sentences for illegally exporting hundreds of luxury vehicles to Russia using comparable diversion routes. Authorities in that instance confiscated nearly €30 million in proceeds.

Industrial Components and Dual-Use Items

• In Finland, authorities have reportedly opened an investigation into a freight-forwarding company suspected of shipping €300,000 worth of sanctioned goods to Russia since 2022. The goods passed through Poland, Lithuania, Bulgaria, Kazakhstan or Kyrgyzstan before reaching their destination.
• In Denmark, a subsidiary of the Swedish manufacturer Alfa Laval pleaded guilty to exporting centrifuge parts to a Russian sister company between June and August 2022. The company was fined 100,000 kroner, or roughly €13,400, even though a director of the company said the exports were never actually completed.
• And Estonia’s courts this year have convicted at least two companies and 12 individuals for various sanctions-related offenses, with sentences ranging from three months (suspended) to five years, alongside fines and asset confiscation. Among the export-related cases, Marine Technics Baltia OÜ was convicted for arranging the export of items, including thermal cameras and a German-manufactured gas generator, to the Russian Ministry of Defence and other military end-users. Marine Technics produced false end-user certificates claiming some of the exports were bound for Turkey, prosecutors said; a member of its board was sentenced to 4 years and 11 months in prison.

Not all export-control violations have involved diversion through third countries, however. In Finland, a 20-year-old Russian student received a suspended 14-month prison sentence for directly purchasing and transporting dual-use goods to Russia. The items included laptops, drones, processors, smartphones and laser rangefinders, worth about €140,000 in all.

European Actions Beyond Exports

But enforcement for Russia sanctions violations in the EU has not just concerned unlawful exports.

One notable example comes from Poland, where authorities detained three people in May for allegedly importing prohibited goods, specifically Belarusian birch plywood, a significant revenue source for Russia and Belarus. The suspects reportedly routed the plywood through companies in Kazakhstan.

• Of note: The European Commission had flagged that exact practice in a sanctions alert issued in March, which warned importers that wood products exported from Kazakhstan, China or Turkey may in fact originate from Russia or Belarus.

The United Kingdom, which also signaled a renewed emphasis on sanctions enforcement in 2025, has brought two cases against firms for a different type of Russia sanctions violation: making funds available for the benefit of sanctioned parties. Another U.K. case concerned a company’s failure to comply with an information request issued by the Office of Financial Sanctions Implementation.

Those three sanctions cases resulted in £622,750 in fines against U.K.-based companies.

The Bottom Line

After years in which enforcement lagged behind policy ambitions, the EU and U.K. are increasingly signaling that sanctions violations will no longer go unchecked. 

Scrutiny of sanctions breaches is likely to remain a priority into 2026, too, as Ukraine’s Western allies increase pressure on Russia to negotiate an end to the war.