This week in our Sanctions Enforcement Around the World series, we bring you the view from Spain. In Spain, fines for sanctions violations are not published but sanctions enforcement actions have been the subject of reports in the press. Generally, the overall sanctions enforcement environment in Spain has not been as active as in other EU Member States. However, in the context of Russia sanctions, there has been a slight uptick in enforcement actions. By…
This week in our Sanctions Enforcement Around the World series, we bring you the view from Poland, an EU member state with a dual sanctions regime. Poland enforces the EU sanctions, in addition to enforcing national sanctions that go beyond the EU sanctions. This post incorporates data on local enforcement activity, as obtained by Baker McKenzie through access to government sources. Until April 2022, Poland did not have specific procedures for enforcement of sanctions, nor…
This week in our Sanctions Enforcement Around the World series, we bring you the view from Sweden, an EU member state that is currently seeing increased sanctions enforcement activity. In Sweden, but also in the Nordic region, the enforcement of sanctions violations has historically been rather low with a handful of criminal enforcement cases. However, during the past 12 months enforcement has been increased significantly, including a number of ongoing criminal investigations mainly driven by…
Having focused on the enforcement of sanctions by Australia, Ukraine, and Switzerland in the past weeks, we now turn our attention to the sanctions enforcement trends in the Netherlands. Recent sanctions enforcement trends in the Netherlands are mainly focused on Russia. Although the Dutch government previously already took a more restrictive (sanctions) policy position towards Russia, this is particularly the case since the Russian invasion of Ukraine last year. According to a letter to parliament of February 2023,…