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…
On 23 January 2026, the European Commission released new FAQ guidance providing clarifications for operators navigating the EU’s expanding Russia sanctions framework. Notably, the European Commission updated their Consolidated FAQs on Sanctions against Russia and Belarus (the “FAQs”, accessible here) with guidance on the Nord Stream transaction ban and the EU’s 19th sanctions package, summarized below. I. Clarifications on the Nord Stream Transaction Ban (Article 5af, Regulation 833/2014) The EU has published dedicated FAQs interpreting…
On 21 January 2026, the EU’s restrictions on the import of refined petroleum products deriving from Russian-origin crude oil entered into force. The restrictions, introduced as part of the EU’s 18th package of sanctions targeting Russia under Article 3ma of EU Regulation 833/2014 (as previously summarised in our blog post here), prohibit the direct or indirect purchase, import or transfer into the EU of refined petroleum products obtained from third countries that derive from Russian-origin…
Background On 15 January 2026, the German Parliament adopted legislation transposing Directive (EU) 2024/1226, which defines and harmonizes criminal offenses and penalties for breaches of all EU restrictive measures (i.e., sanctions). The directive’s core provision, Article 3, sets out a comprehensive list of criminal offenses that cover most types of sanction violations. Transposing the directive into national law, Germany revised key provisions in sections 18 and 19 of the Foreign Trade and Payments Act (Außenwirtschaftsgesetz(AWG))…