How EU is tightening penalties for violating sanctions against Russia and what Kyiv should do

In April 2024, the European Union took a step that the international community had awaited for more than two years after Russia’s full-scale invasion. It adopted Directive 2024/1226 on the criminalisation of sanctions violations.

The Directive set uniform minimum standards for all member states, defining which actions constitute crimes, what penalties should apply and how investigations and interagency cooperation should be organised. Member states were given one year (until 20 May 2025) to adapt their national legislation accordingly.

However, as a study by the think tank Institute of Legislative Ideas has shown, in practice, the process of aligning EU legislation with national legal systems proved to be much more complex than expected.

Read more about the leaders and laggards in this process, the various approaches to adaptation and the challenges for Ukraine in the article by Andrii Klymosiuk of the Institute of Legislative Ideas: Punishment is inevitable? How EU countries are criminalising sanctions violations.

As of July 2025, 18 EU member states had still not notified the European Commission of the full transposition of the Directive into their national laws.

Only Estonia and Finland completed the process on time.

Lithuania, Latvia and Sweden adopted the necessary acts within the deadline, but they entered into force only after the set date.

The Baltic and Scandinavian countries have shown leadership in adapting the Directive. These regions have historically felt the Russian threat most acutely. They chose though different technical approaches to transposition.

In contrast, Slovakia, Denmark, Czechia, Hungary and Cyprus finalised the legislative process with delays.

Greece, Spain, Malta, Germany, Poland and Romania have prepared and published draft implementation acts, which are currently under discussion.

Italy, meanwhile, is significantly behind schedule.

The reasons for missed deadlines vary and are linked to the specific features of national legal systems.

Despite differing approaches to adaptation, most countries have introduced penalties for sanction violations that significantly exceed the Directive’s minimum standards.

This strengthening of penalties shows that states understand not only the legal but also the geopolitical nature of sanction violations since such acts directly assist the aggressor and undermine the EU’s collective efforts to counter aggression.

During the summer of 2025 alone, foreign courts issued seven verdicts, resulting in prison sentences, as well as fines and confiscations exceeding €9 million.

Meanwhile, Ukraine, the country suffering most from Russian aggression, is still in the process of building a similar system.

While partner countries are tightening accountability, Ukraine still lacks a specific provision establishing criminal liability for sanctions violations.

Bill №12406, which aims to correct this, is still awaiting final approval. Before its second reading, it was supplemented with harmful amendments that were criticised by civil society.

For Ukraine, Directive 2024/1226 serves as a clear roadmap for what its legislation should look like on the path toward EU membership. To effectively adapt its provisions, Ukraine needs to adopt a range of key norms (discussed in the full version of the article).

Passing Bill No. 12406 is critically important both for fulfilling EU integration commitments and for protecting national security amid the ongoing war.