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 29 October 2025 and after more than three months, Switzerland finalized the implementation of the EU’s 18th sanctions package by updating the Ordinance on measures in connection with the situation in Ukraine (“Ukraine Ordinance”; see press release here). At the same day, the Federal Council also introduced new measures against Belarus by revising the Ordinance on measures against Belarus (“Belarus Ordinance”). These new measures (with one exception) entered into force on 30 October 2025…
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…
Background Article 8a of Council Regulation (EU) 833/2014 (the “EU Russia Regulations”) imposes obligations on EU parents to undertake “best efforts” to ensure that activities conducted by their non-EU subsidiaries do not undermine EU sanctions targeting Russia and Belarus. This requirement, which was introduced in June 2024, raises complex questions about the scope of EU sanctions and their applicability to the activities of non-EU entities. The Commission previously issued guidance in November 2024 in relation…