The European Commission has launched proceedings against 18 EU countries for violating sanctions legislation

The European Commission has initiated proceedings against 18 EU member states that have failed to implement an EU directive imposing criminal liability for violations and circumvention of restrictive measures. This document was adopted with the aim of harmonizing approaches to the prosecution of sanctions violators, primarily in the context of restrictions imposed on Russia, and became a roadmap for draft law No. 12406, which aims to criminalize such acts in Ukraine and was developed with the involvement of the Institute of Legislative Ideas.

By May 20, 2025, EU member states were required to inform the European Commission about the implementation of the provisions of the directive. However, 18 countries, including Poland, Germany, France, Italy, Spain, Austria, Belgium, Hungary, and others, did not provide such information. In this regard, the European Commission sent them official notices of infringement, to which the states must respond within two months. If the explanations are found to be insufficient, the next step will be a reasoned opinion, followed by a potential referral to the EU Court of Justice.

EU Directive No. 2024/1226, adopted in 2022, obliges member states to criminalize specific forms of sanctions violations, including financial transactions in contravention of prohibitions, illegal export/import of sanctioned goods, or facilitating the circumvention of restrictions.

The European Commission emphasizes that coordinated criminal prosecution for sanctions violations is a key element in ensuring the effectiveness of restrictive measures at the EU level.

The Institute for Legislative Ideas analyzed the Directive and the prospects for its implementation at the national level, which can be found at the link.