Romania implements EU sanctions criminalisation directive

18 December 2025

Romania’s law implementing the EU’s sanctions criminalisation harmonising directive (Directive (EU) 2024/1226) will enter into force tomorrow (19 December 2025). Law 224/2025 will amend Government Emergency Ordinance no. 202/2008 and will insert a new chapter on offences for breaches of EU sanctions (Articles 27^1-27^7). Per the requirements of the harmonising directive:

• Law 224/2025 establishes criminal offences for breaches of EU sanctions including making funds available to sanctioned people/entities, failing to comply with asset freezing measures, providing financial services in breach of EU sanctions, and circumventing/evading EU sanctions. Breaches of these offences are punishable by 1-5 years’ imprisonment, increasing in certain cases (involving military products) to 12 years’ imprisonment (Article 27^1).

• Breaches of EU sanctions by entities may be punished by a fine of up to 670,000 lei (~€130,000).

The EU’s harmonising directive aims to ensure that all EU Member States have similar criminal penalties for sanctions violations. Member States had to implement the harmonising directive into national law by 20 May 2025, but 18 countries, including Romania, failed to do so. Since then, Germany, Poland, Malta, and Luxembourg have taken steps to implement the Directive. Spain has referred a draft law which would implement the Directive to the Spanish Parliamentary Justice Commission. Ireland, Czechia, and Portugal have published draft bills which would implement the Directive which are not yet in force.