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By Maya Lester KC & Michael O’Kane

European Commission sends reasoned opinion to Ireland for failure to notify measures transposing sanctions criminalisation directive

6 October 2026

European Commission sends reasoned opinion to Ireland for failure to notify measures transposing sanctions criminalisation directivespectrumblue/Shutterstock.com

The EU Commission has sent a reasoned opinion to Ireland (INFR(2025)0227) for failing to notify the Commission of measures transposing the Directive on the criminalisation of the violation of EU sanctions (Directive (EU) 2024/1226). Ireland now has 2 months to respond or the Commission may refer Ireland to the CJEU.

Member states had until May 2025 to transpose the Directive into their national law. In July 2025, the Commission sent a letter of formal notice to all member states who did not meet this deadline (including Ireland) and is in the process of sending reasoned opinions (the next step in the Commission’s procedure).

Ireland has begun the process of tranposition. The Criminal Justice (Violation of EU Restrictive Measures) Bill 2025 will be debated in the Irish Parliament  later this year.

A table summarising member state transposition of the Directive is on our EU enforcement pages.

Sanctioning States

Tags

  • Enforcement
  • Criminal Enforcement
Maya Lester KC
By Maya Lester KC

Maya Lester KC is a senior barrister (King’s Counsel) at Brick Court Chambers with a wide-ranging practice in public law, European law, competition law, international law, human rights & civil liberties. She has a particular expertise in sanctions. She is the…

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