After publishing a draft implementing decree (Atto del Governo n. 317) (see our previous blog post here), Italy has now approved final legislation (Legislative Decree No. 211 of 30 December 2025) implementing Directive (EU) 2024/1226 which enter into force on 24 January 2026, significantly changing the criminal enforcement landscape in relation to EU sanctions violations. Legislative Decree No. 211/2025 increases criminal liability risks, particularly in respect of EU sanctions compliance, for companies (under Legislative Decree…
In significant parallel actions this week, the EU and US imposed new sanctions on Russia. While the EU’s 19th sanctions package is much broader in scope, the measures overlap in their focus on the Russian energy sector, with the US imposing full blocking sanctions on Russia’s two largest oil majors, OJSC Rosneft Oil Company (“Rosneft”) and Lukoil OAO (“Lukoil”) and the EU imposing a full ban on Russia-origin liquified natural gas (“LNG”), among other energy sector…
On 10 October 2025, the Italian Government submitted to Parliament the draft legislative decree implementing Directive (EU) 2024/1226 on the definition of criminal offences and penalties for the violation of Union restrictive measures, which mandates the criminalisation of violations of EU restrictive measures. This long-awaited step marks a turning point in Italy’s approach to sanctions enforcement, aligning its legal framework with the EU’s Common Foreign and Security Policy (CFSP). Sanctions Violations Enter the Criminal Code…