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By Maya Lester KC & Michael O’Kane

EU Enforcement

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Overview

Breaches of EU sanctions are investigated and penalised by EU member states, which decide on penalties for breach subject to requirements laid down by the EU.

The enforcement mechanisms and penalties imposed by each member state are on the individual Sanctioning State pages for each country. You can search for enforcement actions taken by member states using the “enforcement tag” on our “advanced search” function and are also reported on by the Mark Handley enforcement blog.  National enforcement legislation and national competent authorities for all member states are found below.

Enforcement for sanctions breaches

Enforcement action for sanctions breaches is the responsibility of member states’ national competent authorities (see the national competent authorities for the enforcement of EU sanctions list), which may initiate investigations in line with their own processes.

Member states’ reporting obligations for sanctions breaches are set out in the EU regulations section on each member state page. Sanctions regime-specific reporting obligations are on our EU Reporting page.

The European Commission has an EU Sanctions Whistleblower Tool, a platform for anonymously reporting past, ongoing or planned sanctions violations, or attempted violations, to the European Commission. More information on this tool is on our EU reporting page.

EU bodies supporting enforcement

EU enforcement bodies support member states with sanctions enforcement:

  • The Freeze and Seize’ Task Force (established in March 2022), helps ensure the enforcement of sanctions against people listed under the EU’s Russia and Belarus sanctions regimes. The Task Force coordinates actions by member states to seize and, where required under provisions of member states’ national law, to confiscate assets of the listed people. It is composed of representatives of the European Commission, contact points from each EU member state, Europol, Eurojust, and other EU agencies and bodies as necessary.
  • European Union Agency for Criminal Justice Cooperation (Eurojust) – works with national authorities to tackle cross-border crimes (including sanctions violations) involving 2 or more countries.

Europol supports member states in preventing and combating all forms of serious international and organised crime, cybercrime and terrorism.

Penalties for sanctions breaches

EU Directive 2024/1126 (adopted in May 2024) aims to harmonise aspects of sanctions enforcement across the EU. Member states had until 20 May 2025 to incorporate its provisions into domestic law. Under the Directive, member states must make sure that penalties for breaching EU sanctions are “effective, proportionate, and dissuasive”.

The Directive requires member state to bring into force laws, regulations and administrative provisions necessary to:

  • Criminalise the intentional violation or circumvention of EU sanctions and the violation of any national provision implementing EU sanctions;
  • Criminalise certain EU sanctions violations if caused by serious negligence;
  • Criminalise inciting, aiding and abetting the commission of offences set out in the Directive;
  • Define criminal conduct violations of EU sanctions;
  • Ensure that effective and proportionate investigative tools are available for investigating or prosecuting those criminal offences;
  • Comply with additional enforcement obligations set out in the Directive.

Definitions of sanctions violations – Articles 3 and 4

Member states are required to criminalise the following conduct (and aiding and abetting this conduct) where it is committed intentional and in violation of an EU sanctions measure:

  1. Making funds or economic resources available to, or for the benefit of, a designated person/ body/ entity;
  2. Failing to freeze funds or economic resources belonging to, or owned, held or controlled, by a designated person/body/entity;
  3. Enabling a designated person to enter/ transit through a state in violation of EU sanctions;
  4. Entering into/ continuing transactions with a third State or bodies controlled by it in violation of EU sanctions;
  5. Trading, importing, exporting, selling, purchasing, transferring, transiting or transporting goods or providing related services contrary to EU sanctions. This will constitute a criminal offence also if committed with serious negligence (at least where conduct relates to items in the Common Military List of the European Union or to dual-use items listed in Annex I and IV to Regulation (EU) 2021/821);
  6. Providing financial services or performing financial activities, in breach of EU sanctions;
  7. Providing other prohibited/ restricted services in breach of EU sanctions;
  8. Circumventing EU sanctions by using/ transferring funds to a third party, providing false or misleading information, failing to comply with an obligation to report funds (or information about funds) to competent administrative authorities;
  9. Failing to report to the competent administrative authorities’ funds (and information about the funds) controlled by a designated body/ their representative.

Member states may provide that the following conduct does not constitute a criminal offence:

a) points (a), (b), and (h) of Article 3 where that conduct involves funds or economic resources of a value of less than EUR 10,000;

b) conduct listed in points (d) to (g) and (i) of Article 3, where that conduct involves goods, services, transactions or activities of a value of less than EUR 10,000.

Where multiple occurrences of prohibited conduct are carried out by the same offender and are of the same kind, their value should be aggregated for the purpose of deciding whether the conduct is not a criminal offence.

Maximum penalties for sanctions breaches – Articles 5,6 and 7

Member states must take necessary measures to ensure that the criminal offences for sanctions breaches are punishable by a maximum penalty of imprisonment.

For individuals:

  • a maximum term of imprisonment of at least 1, 3, or 5 years depending on the offence;
  • a discretion for member states to issue fines, withdraw licences, disqualify individuals from holding certain positions;
  • where there is a public interest, all or part of the judicial decision relating to the offence committed and the penalties imposed may be published – this may include personal data in exceptional cases.

For legal persons: a maximum fine of not less than 1% or 5% of turnover or €8 million or €40 million depending on the offence.

Aggravating and Mitigating Circumstances – Articles 8 and 9

The Directive also requires member states to take necessary measures to ensure that one or more of the following circumstances can, in accordance with national law, be regarded as an aggravating circumstance:

  1. the offence was committed in the framework of a criminal organisation;
  2. the offender used false/forged documents;
  3. the offence was committed by a professional service provider in violation of professional obligations of such a provider, or by a public official when performing their duties;
  4. the offence generated substantial financial benefits or avoided substantial expenses;
  5. the offender destroyed evidence/intimidated witnesses or complainants;
  6. previous convictions for sanctions offences.

Member states must also take the necessary measures to ensure that one or more of the following circumstances can, in accordance with national law, be regarded as a mitigating circumstance:

  • The offender provides information to the competent authorities that they would not otherwise have been able to obtain, which helps them to:
  1. Identify and bring justice to the other offenders;
  2. Find evidence.

Additional obligations – Articles 10 to 19

The Directive also requires member states to:

  • Take necessary measures to enable the freezing and confiscation of assets from certain criminal offences in the Directive;
  • Take necessary measures to provide for a limitation period for investigation, prosecution, trial and adjudication of criminal offences for a sufficient period after the criminal offences’ commission;
  • Take necessary measures to establish its jurisdiction over the criminal offences set out in the Directive;
  • Take necessary measures to ensure that effective and proportionate investigative tools are available and to ensure the protection of persons reporting sanctions violations;
  • Designate a unit or body for ensuring coordination between law enforcement authorities and authorities implementing sanctions;
  • Cooperate with other member states, Europol, Eurojust, the European Public Prosecutor’s Office and the Commission and requires member states to consider sharing information with other member states where the offence is suspected to be of a cross-border nature;
  • Ensure that a system is in place for the recording, production, and provision of statistical data on the investigation and prosecution of the criminal offences and submit them to member states on an annual basis.

Implementation – Article 20

  • The measures adopted must contain a reference to the Directive or be accompanied by a reference to the Directive in their official publication;
  • Member states must inform the Commission of the provisions that are brought into force and communicate the text of the main measures of the law to it.

Implementation of Directive (EU) 2024/1226

The deadline for domestic implementation of the Directive was 20 May 2025. In July 2025 the European Commission began infringement procedures against 18 EU member states for failing to implement the Directive by submitting letters of formal notice. Since the infringement procedures were begun by letters of formal notice, 6 have been closed, leaving 12 open. Of those 12 open procedures, 4 have been escalated by the sending of reasoned opinions, and 8 remain at the letter of formal notice stage.

Of the 8 member states subject to the infringement procedures at the letter of formal notice stage, Italy, Czechia, Hungary and Malta have adopted legislation purporting to implement the Directive, which has been notified to the Commission; the infringement proceedings remain open for now.

Member StateInfringement statusDomestic legislation implementing Directive (EU) 2024/1226
BelgiumLetter of formal noticeProjet de loi implementing Directive (EU) 2024/1226 of the European Parliament and the Council of 24 April 2024 received royal assent on 9 July 2026.
BulgariaLetter of formal noticeThe Ministry of Justice opened public consultations on a Draft Law on Amendments and Supplements to the Criminal Code on 26 June 2026. The public consultation will close on 27 July 2026. It must be authorised by the Council of Ministers before it can be sent to the National Assembly for reading.
SloveniaLetter of formal noticeNo legislative steps to implement the Directive.
IrelandLetter of formal noticeThe General Scheme of the Criminal Justice (Violation of EU Restrictive Measures) Bill 2025 was subjected to pre-legislative scrutiny by the Joint Committee on Justice, Home Affairs and Migration. The Committee must approve the General Scheme before it is drafted into a Bill by the Office of Parliamentary Council.
PolandReasoned opinion received on 8 July 2026The Minister of Foreign Affairs created the Draft law on Restrictive Measures in July 2025.
The Draft law awaits confirmation by the Council of Ministers before it can be submitted to the Sejm.

ItalyLetter of formal noticeImplemented the Directive through Decreto Legislativo 30 Dicembre 2025, n.211 amending its criminal code.
CzechiaLetter of formal noticeImplemented the Directive through zákon č. 270/2025 Sb amending its criminal code.
HungaryLetter of formal noticeImplemented the Directive through Act CXVIII of 2025 Amending Criminal Law Statutes.
MaltaLetter of formal noticeImplemented the Directive through the National Interest (Enabling Powers) Act, 2025.
GermanyClosed infringement procedureImplemented the Directive through the Act on the Adjustment of Criminal Offences and Sanctions for Violations of Restrictive Measures of the European Union. The Commission closed procedures against Germany on 4 June 2026.
CyprusClosed infringement procedureImplemented the Directive through the Criminalisation of Violations of EU Restrictive Measures Act. The Commission closed procedures against Cyprus on 11 March 2026.
PortugalClosed infringement procedureImplemented the Directive through Law n.º 72/2025. The Commission closed procedures against Portugal on 11 March 2026.
RomaniaClosed infringement procedureImplemented the Directive through Law 224/2025. The Commission closed procedures against Romania on 11 March 2026.
GreeceClosed infringement procedureImplemented the Directive through the Definition of offences and penalties against natural and legal persons for the violation of the restrictive measures of the European Union, transposition of Directive (EU) 2024/1226 Act. The Commission closed procedures against Greece on 1 March 2026.
CroatiaClosed infringement procedureImplemented the Directive through the Criminal Codes Amendments Act and the Restrictive Measures Act. The Commission closed procedures against Croatia on 11 March 2026.
AustriaReasoned opinion receivedAmended its National Sanctions Act 2024. The reasoned opinion finds that the amendments fall below the Directive requirements.
SpainReasoned opinion receivedThe Proyecto de Ley Orgánica 121/000072 implementing the Directive was submitted to the Spanish Congreso in October 2025. It remains in the amendments stage of the Comisión de Justicia.
FranceReasoned opinion receivedProjet de loi n.2544 was proposed to the National Assembly to implement the Directive in March 2026. It has been referred to the Commission des lois constitutionnelles, de la législation et de l'administration générale de la République and awaits consideration
EstoniaNo infringement procedureImplemented the Directive through 3 instruments: Act Amending the Criminal Code and Related Acts — sanctions violations, Act Amending the Whistleblower Protection Act and the International Sanctions Act — Union restrictive Measures Directive, and International Sanctions Act — further Amendments.
LithuaniaNo infringement procedureImplemented the Directive through a package of laws amending the Criminal Code and its annex (Law No.XV-204), the annex to the Code of Administrative Offences (Law No. XV-205), the Law on International Sanctions (Law No.XV-203), the Law on Criminal intelligence (Law No.XV-206) and the Law on the Protection of Informants (Law No.XV-207).
LatviaNo infringement procedureImplemented the Directive through three Acts: Amendments to the Criminal Law Act, Amendments to the Criminal Law Transitional Provisions Act, and Amendments to the International and National Sanctions Act.
The NetherlandsNo infringement procedureCommunicated to the Commission that existing Dutch law implements the Directive requirements.
SlovakiaNo infringement procedureImplemented the Directive through Act No. 157/2025 amending its Criminal Code.
FinlandNo infringement procedureImplemented the Directive through Criminal Code amendment (Law 179/2025), the UN/EU obligations fulfilment Act amendment (Law 182/2025), the Coercive Measures Act amendment (Law 180/2025) and the EU law whistleblower protection Act amendment (Law 181/2025).
SwedenNo infringement procedureImplemented the Directive through Law on International Sanctions (2025:327) and related amendments.
LuxembourgNo infringement procedureIntroduced Projet de loi no. 8579 to the Chambre des Députés to implement certain provisions of the Directive. Luxembourg has notified existing criminal codes to the Commission, as existing export control legislation criminalise breaches of restrictive measures.
DenmarkNo infringement procedureDenmark is not bound by the directive in accordance with Articles 1 and 2 of Protocol 22 annexed to the TFEU – see recital 39 of the Directive.

Denmark voluntarily strengthened its domestic criminal law on sanctions enforcement in a manner consistent with the Directive through Act No.731 of 20 June 2025 amending the Criminal Code (Restrictive Measures).

 

Member States enforcement legislation

EU member stateLegislation for sanctions enforcement
AustriaForeign Trade Act 2011

Federal Act on Sanctions 2024
BelgiumArticle 6 Law of 13 May 2003
BulgariaLaw on Measures against the Financing of Terrorism and the Proliferation of Weapons of Mass Destruction

Article 233, Article 339b, Bulgaria Criminal Code
CroatiaArticle 21, Article 22 Law on Restrictive Measures (Official Gazette 133/2023) (amended by Law on Amending the Law on Restrictive Measures (Official Gazette 151/2025)).
CyprusCriminalisation of Violations of EU Restrictive Measures Act. (149(1)/2025)

Articles 136 and 137 Cyprus Criminal Code (Cap. 154)

Article 4 The Implementation of the Provisions of the Resolutions or Decisions of the United Nations Security Council (Sanctions) and of the Decisions and Regulations of the Council of the European Union (Restrictive Measures) Law of 2016 (L. 58(I)/2016)
Czech RepublicSection 410 of the Criminal Code (amended by zákon č. 270/2025 Sb)

Law No 69/2006 Coll


Act No. 270/2025 and Act 166/2024 Sb


Act no. 253/2008 Coll
DenmarkDanish Criminal Code, Section 110C (amendment under Act Amending the Criminal Code (Act No. 731, 20 June 2025)
EstoniaInternational Sanctions Act (International Sanctions Act — further Amendments)

Section 931 of the Estonian Penal Code


Act Amending the Criminal Code and Related Acts — sanctions violations


Act Amending the Whistleblower Protection Act and the International Sanctions Act — Union restrictive Measures Directive
FinlandAct on the Enforcement of Certain Obligations of Finland as a member of the United Nations and of the European Union

Chapter 46, section 1 (11) of the
Finnish Penal Code

Criminal Code amendment (Law 179/2025)

The UN/EU obligations fulfilment Act amendment (Law 182/2025)

The Coercive Measures Act amendment (Law 180/2025)
FranceArticle 459 of the French Customs Code


Article L2335-2 and Article L2339-11-1 of the French Defence Code


Article L574-3 of the Monetary and Financial Code
GermanyAußenwirtschaftsgesetz (Foreign Trade and Payments Act)


Sanktionsdurchsetzungsgesetz (Sanctions Enforcement Act)


Act on the Adjustment of Criminal Offences and Sanctions for Violations of Restrictive Measures of the European Union
GreeceDefinition of offences and penalties against natural and legal persons for the violation of the restrictive measures of the European Union, transposition of Directive (EU) 2024/1226 Act.
HungaryAct C of 2012 on the Hungarian Criminal Code 2001 CIV - Law on Criminal Measures Applicable to Legal Persons


Act CXVIII of 2025 Amending Criminal Law Statutes.


Act LII of 2017 on the Implementation of Financial and Asset-Related Restrictive Measures Ordered by the EU and UNSC
IrelandViolation of EU sanctions is regulated by specific statutory instruments which impose criminal sanctions for the breach of specific sanctions regimes.
ItalyArticle 2 of Law-decree No 369 of 12 October 2001


Article 55-58 of Legislative Decree No 231 of 21 November 2007


Decreto Legislativo 30 Dicembre 2025, n.211
LatviaS84 Criminal Law of the Republic of Latvia

Amendments to the Criminal Law Act


Amendments to the Criminal Law Transitional Provisions Act


Amendments to the International and National Sanctions Act
LithuaniaArticle 123(1) of the Criminal Code of the Republic of Lithuania

Article 515 of the Code of Administrative Law Violations of the Republic of Lithuania


Law of the Republic of Lithuania on Implementation of Economic and other International Sanctions
Amendments to the Criminal Code

Law No.XV-204, to the Code of Administrative Offences (Law No. XV-205), the Law on International Sanctions (Law No.XV-203), the Law on Criminal intelligence (Law No.XV-206) and the Law on the Protection of Informants (Law No.XV-207).
LuxembourgCode pénal


Version consolidée applicable au 20/08/2023: Loi du 8 avril 2018 sur les marchés publics.


Version consolidée applicable au 24/07/2022 : Loi du 19 décembre 2020 relative à la mise en oeuvre de mesures restrictives en matière financière.
MaltaNational Interest (Enabling Powers) Act, 2025.
NetherlandsWet op de economische delicten (WED, Law on Economic Offences)

Sanctions Act 1977
PolandUstawa z dnia 13 kwietnia 2022 roku o szczególnych rozwiązaniach w zakresie przeciwdziałania wspierania agresji na Ukrainę oraz służących ochronie bezpieczeństwa narodowego

Ustawa z dnia 06 czerwca 1997 roku - Kodeks karny

Ustawa z dnia 28 października 2002 roku o odpowiedzialności podmiotów zbiorowych za czyny zabronione pod groźbą kary
PortugalLaw n. 97/2017 (as amended by Law n. 72/2025)

Law n.5/2002 (as amended by Law n. 72/2025)
RomaniaGovernment Emergency Ordinance No 202 of December 2008 on the implementation of international sanctions (amended by Law 224/2025)
SlovakiaAct No 289/2016 on the implementation of international sanctions (amended by Act No. 157/2025)
SloveniaRestrictive Measures Act introduced or implemented by the Republic of Slovenia in accordance with legal acts and decisions adopted within the framework of international organisations
SpainAct 10/2010 on the prevention and blocking of terrorism financing (amending Act 12/2003 and Act 19/2003)

Criminal Code Articles 301-303
SwedenLaw on International Sanctions (2025:327)

EU Member State enforcement actions

Further enforcement actions by European countries are reported on the European Sanctions Enforcement blog.

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