On 9 June 2023, the EU Council published draft legislation introducing EU-wide criminal penalties and stricter enforcement for the evasion of EU sanctions. The EU Council’s press release explains that it has settled its position on the terms of new legislation to align criminal offences and penalties across the EU, before commencing negotiations with the European Parliament on its finalisation. Currently, Member States are not obligated to criminalise sanctions circumvention, however, once finalised, Member States…
This week in our Sanctions Enforcement Around the World series, we bring you the view from Spain. What are the recent sanctions enforcement trends in 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…
On Monday 5th June, the EU published an amendment to the existing sanctions against Russia, which came into force on Monday 5th June. The implementing regulation is available here. These measures permit the designation of leading business persons operating in Russia, along with: immediate family members; other natural persons benefitting from them; and business persons involved in economic sectors providing a substantial source of revenue to the Russian Government. These amendments were made on the…
This week in our Sanctions Enforcement Around the World series, we bring you the view from Poland, an EU member state with a dual sanctions regime. Poland enforces the EU sanctions, in addition to enforcing national sanctions that go beyond the EU sanctions. This post incorporates data on local enforcement activity, as obtained by Baker McKenzie through access to government sources. What are the recent sanctions enforcement trends in Poland? Until April 2022, Poland did…