Clifford Chance

The new Directive, aimed at harmonising criminal enforcement of EU sanctions regimes, will enter into force on the twentieth day following publication in the Journal on 29 April 2024.

On 12 April 2024, the Council of the EU approved the EU Directive to establish minimum rules concerning the definition of criminal offences and penalties for violations of EU sanctions, in an effort to harmonise enforcement and ensure consistency.

Once the Directive comes into force, Member States will have 12 months to ensure their laws are amended in line with the EU Directive, in particular by providing "effective, proportionate, and dissuasive" criminal penalties. This includes criminal penalties applicable to violations by individuals and legal entities.

Click here to read our full briefing on the key provisions of the new Directive, as well as our analysis of the impact of the Directive on national regimes in Belgium, the Czech Republic, France, Germany, Italy, Luxembourg, the Netherlands, and Poland, as well as our outlook on enforcement trends.