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