Council of EU approves law criminalising sanctions circumvention and violations

Friday, 12 April 2024 —

On Friday 12 April, the Council of the European Union finally approved a law on EU-wide minimum rules for the prosecution of violations or circumvention of EU sanctions in member states.

As reported by the press service of the Council, effective immediately, specific actions aimed at evading sanctions will be considered criminal offences in all member states. Such offences include helping to bypass the entry ban, trading in sanctioned goods, or conducting prohibited financial activities.

Inciting, aiding and abetting these offences will also be penalised.

EU member states must ensure that breaches of EU sanctions result in effective and proportionate criminal penalties, which vary depending on the offence.


Intentional violation of sanctions carries a prison sentence as the maximum penalty.

Those who violate EU restrictive measures may also be subject to fines.

In addition, legal entities may be held liable if an offence is committed by a person holding a senior position within the organisation.

The directive will enter into force on the 20th day after it is published in the Official Journal of the European Union.

Member states will have 12 months to transpose the provisions of the directive into their national legislation.

In response to Russia's aggression against Ukraine, the EU has adopted an unprecedented number of restrictive measures to undermine Russia's economy and limit its ability to wage war.

The European Commission has proposed to adopt this directive in December 2022 to limit the circumvention of sanctions and strengthen their implementation.

On 12 March this year, the European Parliament voted in favour of a directive criminalising the violation and circumvention of EU sanctions.

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