Two more EU Member States move forward with the implementation of Directive 2024/1226

Romania has completed the transposition of EU Directive 2024/1226, which provides for criminal liability for violations and circumvention of sanctions. The relevant law entered into force on 19 December 2025.

The legislation establishes criminal liability for providing funds or economic resources to sanctioned persons, failing to comply with asset-freezing requirements, providing prohibited financial services, and participating in schemes to circumvent sanctions. For individuals, penalties range from 1 to 5 years’ imprisonment, and in aggravated cases – particularly those involving military goods – up to 12 years in prison. Companies face fines of up to €130,000.

Italy’s Council of Ministers has also approved a draft legislative decree transposing the Directive. The document is awaiting the President’s signature, after which it is expected to enter into force. If adopted, sanctions violations would entail imprisonment and fines of €50,000–250,000 for individuals, and fines of up to 5% of annual turnover for companies.

As shown by a study conducted by the Institute of Legislative Ideas on the implementation practices of EU Directive 2024/1226, both Italy and Romania missed the established transposition deadline. At the same time, the criminalization models they developed generally comply with the Directive’s requirements, indicating the continuation of a pan-European trend toward strengthening criminal enforcement for serious sanctions violations.

In contrast, in Ukraine – now in the fourth year of the full-scale war – there is still no specific legal provision establishing criminal liability for sanctions violations. The relevant draft law No. 12406 has been pending in parliament for almost a year, despite its adoption being critically necessary to enhance the effectiveness of sanctions policy.