The European Council adopted the Directive on the introduction of criminal offences for breaches of EU sanctions on 12.04.2024. The regulation is based on a proposal by the European Commission and aims to restrict attempts to circumvent restrictive measures in a more targeted manner across the EU.

The act defines in detail which actions by natural or legal persons constitute a criminal offence under the new law. As a result, persons who trade with sanctioned goods, carry out prohibited financial activities or assist in circumventing travel bans face significant criminal penalties. Incitement, aiding and abetting as well as attempts to disregard imposed sanctions are also considered criminal offences in the legal text.

The new law could result in prison sentences of several years for natural persons and accompanying penalties that are proportionate to the severity of the offence. Legal entities convicted of criminal offences, on the other hand, could face the withdrawal of licenses, permits or other public benefits, including the closure of affected institutions by court order.

The law enters into force on the 20th day following its publication in the Official Journal of the European Union. The EU member states will then have 12 months to make the necessary adjustments to their national legal and administrative provisions.

The directive can be seen as a direct response to the Russian war of aggression against Ukraine. To circumvent existing sanctions imposed by the EU, government-related Russian organizations are constantly looking for new ways and methods.


Sources: European Council, →Directive (