Austria
The Austrian National Bank (OeNB) is responsible for monitoring compliance, granting exemptions, and issuing financial sanctions against certain individuals. Responsibility will transfer to the FMA in 2026.
Sanctions breaches are punishable as criminal offences or administrative offences (under §§16-18 of the Sanctions Act 2024 and section 2 of the Foreign Trade Act 2011) depending on the value of the offence.
Breaches of financial sanctions and prohibitions on providing services are criminal acts punishable by imprisonment from 6 months to 5 years if the value of the funds, economic resources or services exceeds EUR 100k.
Breaches below this value threshold and infringements of licensing and reporting obligations are punishable with administrative penal provisions, which include fines of up to €150,000 by the district administrative authority. Serious or repeated infringements of reporting obligations may be subject to fines of up to €5 million (or double the economic benefit resulting from the infringement; for companies, the maximum fine will increase to up to 10% of consolidated turnover as of 1 January 2026).
The Export Control Department of the Federal Ministry of Labour and Economy (BMAW) is responsible for goods-related sanctions.
Violations of goods-related sanctions are criminal acts punishable by imprisonment of up to 3 years, or 6 months up to five years if the violation is committed with the intention of obtaining a continuous income. Negligent violations of goods embargos are punishable by imprisonment of up to one year, or a monetary fine. Companies may be liable for violations under the Association Responsibility Act, which provides for fines of up to EUR 3 million.
Cyprus
The Prevention and Suppression of Money Laundering and Terrorist Financing (Law No. 188(I)/2007 as amended) empowers courts to issue a confiscation order in relation to the proceeds of the illegal activities.
Estonia
Chapter 6 of the International Sanctions Act and § 931 of the Estonian Penal Code governs enforcement of sanctions.
If a person knowingly performs services for a person/entity subject to sanctions, they risk a fine or up to 5-years imprisonment An entity that does the same will be fined. The offence is classified as an offence against humanity and international security.
The following are classified as misdemeanours and are punishable by detention (no more than 30 days) or fines of up to €1200 when committed by a person, or a fine of up to €400k when committed by an entity:
- failure to notify the FIU of the identification of a subject of financial sanctions or a transaction violating financial sanctions
- failure (by a financial or credit institution) to appoint a board member responsible for notifications to the FIU
- failure to identify and update a risk assessment for international sanctions
- failure to apply due diligence measures when establishing/during a business relationship
- failure to establish and comply with rules of procedure and internal control rules and failure of employee of person with special obligations (see Reporting) to implement them
- breach of an obligation to provide (additional) information
Violations of reporting obligations or obligations to collect/store data are punishable by a fine (up to €1200 for people and €400k by entities).
Violations of prohibitions on the import and export of goods/cash under international or autonomous sanctions is punishable by the following where the value does not exceed €10k: a fine of up to €1200 for people and €400k for entities.
The following bodies are involved in enforcement:
Germany
Sections 18 and 19 of the Foreign Trade Act provide that violations of financial sanctions laws can be punished as a criminal offense or administrative offense.
Ireland
S.I. No. 77/2024 – European Union (Restrictive Measures concerning Ukraine) (No.3) Regulations 2024 provides that contravention of EU sanctions on Russia or contravention of an authorisation (licence) shall be liable:
(a) on summary conviction to a class A fine or imprisonment for a term not exceeding 12 months or both or;
(b) on conviction on indictment a fine not exceeding €500,000 or to imprisonment for a term not exceeding 3 years or both.
Other statutory instruments provide for the same penalties for other sanctions regimes.
Malta
The Sanctions Monitoring Board may impose “one-time fixed” penalties or “daily cumulative” penalties for sanctions breaches.
One-time fixed sanctions range from €100 to €300 for every separate contravention and from €300 to €800 for serious, repeated and systematic contraventions. Daily cumulative penalties range from €50 to a total of €1000.
In addition, the Board may issue directives requiring any person to take action to remedy a sanctions contravention.
Any individual or company may request specific guidance from the Sanctions Monitoring Board on whether any intended action or transaction would fall foul of applicable sanctions.
Netherlands
Sanctions violations are a criminal offence under the Dutch Economic Offences Act.
Where there is intention to breach sanctions, the breach constitutes a felony in Dutch law. Those convicted of a felony can have imposed:
- a prison sentence of up to 6 years;
- a community service order; or
- a fine of up to €103k.
Where the breach was not intentional, it constitutes a misdemeanour. The possible penalties for a misdemeanour are:
- a prison sentence of up to 1 year;
- community service; or
- a fine of up to €25,750.
Additional measures may also be taken, including:
- deprivation of certain rights (holding offices/certain offices, serving in the army, the right to elect members of general representative bodies and be elected to such bodies, being a counsellor/judicial administrator, the exercise of certain professions);
- complete or partial closure of a business;
- confiscation of certain objects;
- confiscation of objects belonging to a business;
- denial of certain benefits in connection with the convicted person’s business for up to 2 years; and
- publication of the judicial decision.
Spain
Under Articles 51 and 52 of Law 10/2010, a violation of sanctions may result in a monetary penalty of between €60,000 to €5 million, a public or private warning, and fines and disqualification on managers of an entity which contravenes sanctions