Why is Finland a leading enforcer of EU sanctions?

Finland's geographic position as Russia's direct neighbour, strong customs capabilities, and long experience with cross-border trade risks make it one of the EU's most proactive sanctions enforcers. Since the outbreak of the war in Ukraine, Finland has launched nearly a thousand criminal investigations related to sanctions violations, with close to a hundred convictions.

What are common red flags in Central Asian trade routes?

Unusual export destinations, companies with no prior trade history to the region, inconsistent or falsified documentation, and rerouting of goods through high-risk countries such as Kazakhstan or Kyrgyzstan are major warning signs. Finnish Customs has warned that companies should not be naïve about the true end-use of goods exported to these jurisdictions.

What penalties exist for sanctions violations in Finland?

Aggravated sanctions violations carry imprisonment of four months to five years for individuals. Individual criminal liability can apply even when a company structure is used. Under 2025 amendments to the Finnish Criminal Code, companies can also face corporate fines of up to 5% of annual turnover, with a minimum of €850,000 and a maximum of €40 million.

How can companies strengthen their sanctions compliance framework in Finland?

Companies should conduct regular sanctions risk assessments, implement due diligence procedures for customers and supply chains, establish internal sanctions compliance policies, train relevant staff, and carefully document all compliance measures. Finnish law requires businesses to know their end customers and the ultimate use of goods, particularly for exports to high-risk jurisdictions.

Sanctions Enforcement and Compliance in Finland | What Businesses Need to Know

July 21, 2025 at 7:42 am

Sanctions Compliance in Finland: Enforcement, Risks & Corporate Liability | LKOS Law Office

Finland's Strong Position on Sanctions Enforcement

Since the outbreak of the war in Ukraine, Finland has emerged as one of the EU's most active enforcers of sanctions legislation. Authorities have launched nearly a thousand criminal investigations related to sanctions violations, with close to a hundred convictions—placing Finland among the leading EU countries in terms of enforcement activity.

This assertiveness is not due to more extensive legal powers than elsewhere in the EU. Instead, it reflects Finland's unique geographic and institutional context: as Russia's direct neighbour and a long-standing trade partner, Finland has developed extensive experience in managing cross-border trade risks, including customs fraud, tax evasion, and now, sanctions circumvention.

Customs Capabilities and Red Flags in Trade with Central Asia

One enforcement priority is the increasing use of Central Asian countries as transshipment points. Finnish Customs has publicly warned that companies should not be naïve about the true end-use of goods exported to countries such as Kazakhstan and Kyrgyzstan. For example, in early 2023, 257 EU-registered companies, none with a previous export history to Central Asia, used Finland for export clearances, prompting investigations.

Authorities rely on comprehensive evidence: customs records, transport documentation, falsified or manipulated paperwork, and cooperation with foreign customs. International intelligence and logistics data help trace onward movements of goods, especially when rerouted to Russia.

Legal Consequences for Individuals and Companies

Under Finnish law, aggravated sanctions violations (FI: törkeä pakoterikos) carry penalties ranging from four months to five years of imprisonment. Finnish legislation permits individual criminal liability even when a company structure is used. If a person directs or controls a company in a way that facilitates or conceals the offense, they may be held personally accountable regardless of corporate separation.

In 2025, Finland amended its Criminal Code to introduce corporate liability for sanctions violations and other trade-related offenses. Companies can now face fines of up to 5% of annual turnover, with a minimum of €850,000 and a maximum of €40 million.

How LKOS Law Office Supports Your Business

At LKOS Law Office, we help companies navigate the complex and rapidly evolving field of EU sanctions and export control compliance. Our services include:

Risk assessments and compliance reviews
Advice on dual-use goods and licensing obligations
Drafting internal policies and due diligence procedures
Representation in enforcement or criminal proceedings
Strategic consultation on trade structuring and supply chain integrity

We understand that sanctions compliance is not just a legal issue—it's a strategic business concern. Our practical, business-minded approach ensures that your company meets legal obligations without compromising operational efficiency.

Contact Our Sanctions & Trade Law Experts

If your business is engaged in cross-border trade, manufacturing, or logistics, you face potential exposure to sanctions risks. Our team is here to help you stay compliant, mitigate liability, and act decisively if issues arise.

📍 Contact LKOS Law Office to speak with one of our sanctions law experts.