EU Sanctions Criminalisation Directive: Three Member States Face Escalated Infringement Proceedings
Directive (EU) 2024/1226 — which establishes criminal offences and penalties for the violation or circumvention of EU sanctions — entered into force on 19 May 2024, with a transposition deadline of 20 May 2025 for all EU member states.
The Directive requires member states to introduce criminal penalties for sanctions violations committed through specific conduct, setting out minimum penalties and limitation periods. Member states retain discretion over whether to criminalise prohibited conduct involving funds, goods, or services valued at less than €10,000.
Following the missed deadline, the European Commission launched infringement procedures in July 2025 against 18 member states by issuing letters of formal notice. The current status of those proceedings is as follows:
The Directive requires member states to introduce criminal penalties for sanctions violations committed through specific conduct, setting out minimum penalties and limitation periods. Member states retain discretion over whether to criminalise prohibited conduct involving funds, goods, or services valued at less than €10,000.
Following the missed deadline, the European Commission launched infringement procedures in July 2025 against 18 member states by issuing letters of formal notice. The current status of those proceedings is as follows:
- 6 procedures closed — Germany, Cyprus, Portugal, Romania, and Croatia have successfully transposed the Directive and their cases have been resolved
- 3 procedures escalated — Spain, France, and Austria have each received a reasoned opinion, representing a formal escalation of the infringement process
- 9 procedures ongoing — Italy, Czechia, Hungary, and Malta are among those that have adopted domestic transposing legislation since proceedings were initiated, though their cases remain open
- The Commission has not initiated infringement procedures against Denmark, Estonia, Lithuania, Latvia, Slovakia, Finland, Sweden, the Netherlands, or Luxembourg.
