On March 25, 2025, the Spanish Council of Ministers approved a draft bill to implement Directive (EU) 2024/1226 on the definition of criminal offenses and penalties for the violation of Union restrictive measures and amending Directive (EU) 2018/1673 (“Draft Bill” and “Directive”, respectively). The Directive established minimum Member State requirements concerning the definition of criminal offenses and penalties for the violation and circumvention of EU sanctions. For further detail on the Directive, see our blog post…
As anticipated in its press release, the EU yesterday published in the Official Journal the first legal instruments underpinning its decision to progressively suspend its sanctions against Syria: Decision 2025/406/CFSP, Council Regulation 2025/407 and Council Implementing Regulation 2025/408. The measures include the suspension of a significant number of sanctions which have been in place for over a decade, most recently contained within Council Regulation 36/2012, as summarised below. Companies considering business in Syria previously restricted…
This week in our Sanctions Enforcement Around the World series, we bring you the view from Spain. In Spain, fines for sanctions violations are not published but sanctions enforcement actions have been the subject of reports in the press. Generally, the overall sanctions enforcement environment in Spain has not been as active as in other EU Member States. However, in the context of Russia sanctions, there has been a slight uptick in enforcement actions. By…