EU member state transposition of the EU sanctions criminalisation directive

18 June 2026

Directive (EU) 2024/1226 on the definition of criminal offences and penalties for the violation of Union restrictive measures entered into force on 19 May 2024.

It requires EU member states to provide criminal penalties for the violation or circumvention of EU sanctions, where the violation is committed by specific conduct. Minimum penalties and limitation periods are specified in the directive. Member states can decide whether prohibited conduct involving funds, goods, and services valued at less than EUR 10,000 is to be criminalised. The Directive’s requirements are on our EU Enforcement page.

The deadline for domestic implementation of the Directive was 20 May 2025. In July 2025 the European Commission began infringement procedures against 18 member states for failing to transpose the Directive by submitting letters of formal notice. Since the infringement procedures were begun by the letters of formal notice:

• 6 have been closed (Germany, Cyprus, Portugal, Romania, Croatia),

• 3 have been escalated (Spain, France, and Austria) by sending reasoned opinions,

• 9 are ongoing (Italy, Czechia, Hungary and Malta have adopted domestic transposing legislation since procedures were initiated).

The Commission has not initiated infringement procedures against Denmark, Estonia, Lithuania, Latvia, Slovakia, Finland, Sweden, the Netherlands or Luxembourg.

Visit our EU Enforcement page to find up-to-date member states' domestic transposition legislation. National transposition measures communicated by member states to the Commission are published by the European Union.