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Eric Lasry (France)

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France has taken its first formal step toward implementing Directive (EU) 2024/1226, which requires all EU Member States to criminalise the violation and circumvention of EU restrictive measures. The Directive was adopted to address persistent divergences in national enforcement regimes and to ensure that breaches of EU sanctions are treated consistently as criminal offences across the European Union (EU). The Directive establishes a minimum harmonisation of offences and penalties, covering conduct such as providing funds…

The French authorities (French Treasury – Direction Générale du Trésor) have provided an important update for operators in France regarding the renewal of licenses for the provision of intragroup services and software to Russia. Under Article 5n of Regulation (EU) 833/2014 (“EU Russia Sanctions Regulation”), the supply of certain services and software to persons established in Russia is prohibited. However, until 30 September 2024, the supply of these services and software to Russian entities owned…