The study analyzes the approaches of 16 EU Member States to the implementation of Directive (EU) 2024/1226 on the definition of criminal offences and penalties for the violation of Union restrictive measures

The Institute of Legislative Ideas has presented a new analytical report titled “Practices of Transposing EU Directive 2024/1226 by Member States: Defining Criminal Offences and Penalties for Violations of Union Restrictive Measures.”
The document explores how EU countries criminalize sanctions violations and introduce unified standards of liability for their circumvention.

The research examines legislative decisions of 16 EU Member States that have already begun implementing the Directive. The ILI team systematized key approaches related to:

• defining criminal offences and forms of sanctions circumvention;

• implementation models (through amendments to criminal codes or adoption of special acts);

• types of sanctions, imprisonment terms, and aggravating circumstances;

• procedural mechanisms and interagency coordination during transposition.

A separate section is dedicated to Ukraine, providing practical recommendations on how to adapt national sanctions legislation to EU standards and fulfill upcoming obligations within the European integration process.
The study will be useful for lawmakers, legal practitioners, and experts working to strengthen the country’s sanctions policy.

The research was prepared by the think tank Institute of Legislative Ideas with the support of the Askold and Dir Foundation, administered by ISAR Ednannia under the project “Strong Civil Society of Ukraine – a Driver of Reforms and Democracy”, funded by Norway and Sweden.
The content of the study is the sole responsibility of the Institute of Legislative Ideas and does not necessarily reflect the views of the Governments of Norway, Sweden, or ISAR Ednannia.

You can read the full study here.