Enforcement of sanctions: increased controls on circumvention and violations

Introduction

In recent years, EU foreign policy has increasingly focused on the use of restrictive measures as a key instrument. Russia’s invasion of Ukraine was a decisive catalyst for the increase of sanctions regimes: the G7 countries and their allies reacted mainly on the economic and trade level, making Russia the most sanctioned country in the world. As of February 2022, Russia, with more than 5000 restrictive measures applied, has in fact surpassed Iran, Syria and North Korea in the number of sanctions.

In parallel with the expansion of sanction regimes, European authorities, together with those in the Member States, the UK, the US and other countries, have significantly intensified their controls to ensure that economic operators comply with the new restrictions. These controls are carried out not only by judicial authorities, but also by financial supervisory bodies, customs and other competent bodies according to local jurisdictions. This is the background to Directive (EU) 2024/1226, which defines criminal offences and penalties for the violation of Union restrictive measures.

In recent months, authorities and media have reported numerous cases of investigations, prosecutions and sentences for alleged or confirmed violations of sanctions regimes by companies and individuals. This SRA – Sanctions Risk Analysis offers an up-to-date analysis of some of the most recent measures taken worldwide, with the aim of illustrating the potential consequences of poor risk management of international sanctions regimes and the importance of having adequate monitoring systems in place.

News

01.11.2024: German customs confiscate 8 luxury cars destined for the Russian market in violation of EU sanctions. The public prosecutor’s office in Würzburg is investigating against a German car dealer accused of exporting luxury vehicles with a total value of more than EUR 10 million. In addition to the confiscation of the vehicles, customs authorities searched several premises of the company in Aschaffenburg and confiscated its bank deposits.