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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…

On 4 December 2025, the UK Office of Trade Sanctions Implementation (“OTSI”) published a corporate report marking the first year since its launch in October 2024 (see here). Our previous blog post providing more background on OTSI’s powers and jurisdiction can be found here. The corporate report summarises OTSI’s activities during this first year, including licensing and enforcement activity, efforts to engage with businesses, collaboration with international partners and other government functions, as well as…

Join us online for our 46th Global Year-End Review of Import/Export & Trade Compliance Developments Conference, a multi-panel webinar series featuring expert insights on key global trade topics. This three-day online series features nine substantive sessions (three each day) designed to help you navigate the evolving trade landscape. Join our international trade compliance lawyers from around the world for in-depth discussions on sanctions and export controls, imports and customs compliance, enforcement, global and regional regulatory…

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…