Belgium submits draft law on EU sanctions criminalisation directive to Parliament

23 June 2026

Belgium has submitted its draft law transposing the EU’s sanctions criminalisation directive (Directive (EU) 2024/1226) for consideration by Parliament. The Directive seeks to harmonise penalties for breaches of EU sanctions across EU member states. The Bill would amend Belgium’s criminal code to:

• Create 9 sanctions offences under proposed Article 16, including making funds available to designated people and entities, failing to freeze funds, and circumventing restrictive measures.

• Punish intentional breaches with up to 5 years’ imprisonment, the current maximum under Belgium’s sanctions law.

• Apply the same maximum to grossly negligent acts involving military goods or dual-use goods on the EU lists.

• Let courts add a fine of €200 to €2,000,000 for a person convicted of an offence.

• Set fines for companies of €15,000 to €30,000,000 for less serious offences, rising to €75,000 to €150,000,000 for more serious offences.

• Allow the freezing and confiscation of funds and economic resources linked to the offence.

• Treat all breaches as criminal regardless of value (Belgium did not take the directive’s option to exclude breaches below €100,000).

Belgium missed the 20 May 2025 deadline to transpose the Directive into national law. The EU has begun infringement proceedings against Belgium, by sending a reasoned opinion (formal warning). Our EU enforcement page contains further information on Directive (EU) 2024/1226 and includes a table that sets out implementation steps taken by EU member states. For more information on Directive (EU) 2024/1226, see our EU enforcement page which includes a table of each member state’s implementation steps.