Given the intensity and pace of change related to sanctions following the Russian invasion of Ukraine, EU Member States have been very focused on the need to move swiftly and flexibly within the sanctions landscape. The Czech Government is clearly signalling its intent to use sanctions powers and tools more readily than it perhaps has done historically.

The Czech Republic has adopted the Sanctions Act, which implements the process for including the entities on the Czech national sanctions list (the “NSL“) or the EU sanctions list (the “EUSL“) and the rules for adopting national restrictive measures against certain entities for actions sanctionable under the relevant EU regulation.

The Sanctions Act responds to situations where a restrictive measure cannot be achieved at the EU level or where the length of the approval process does not allow for a flexible response to the situation. The Sanctions Act published as the Act No. 1/2023 Coll., on restrictive measures against certain serious acts in international affairs (Sanctions Act), enters into force on 3 January 2023.

Listing Procedures

The listing procedure is ensured by the Ministry of Foreign Affairs (the “Ministry“) and the Government of the Czech Republic. The task of the Ministry is to collect, verify and evaluate the grounds for inclusion of entities on the NSL or the EUSL and to submit a proposal to the Government for the inclusion, change or removal of an entity from the relevant sanctions list.

The Ministry may propose to include an entity on the NSL and, at the same time, submit a proposal to the EU authorities to include the entity in the EUSL. In addition, the Ministry may submit a proposal to include an entity on the NSL, although it has already been included in the EUSL, if the Ministry considers it necessary to apply further restrictive measures to the entity concerned.

The proposal to the Government shall include, inter alia, the following information:

  1. a description of the punishable act committed by the relevant entity;
  2. a reference to the provision of the relevant EU regulation; and
  3. restrictive measures (either under the EU regulation, or under the Czech Act No. 69/2006 Coll., on the Implementation of International Sanctions, as amended) to be imposed on the relevant entity.

Upon a receipt of the proposal submitted by the Ministry, the Government shall decide whether to include the relevant entity on the NSL or the EUSL. In the event of a decision to propose an entity to be included on the EUSL, the Government shall also decide on the inclusion of the entity on the NSL, if the entity is not included on the European Union sanctions list within one month of the proposal.

The Government’s decision to include an entity on the NSL must always include the scope of the restrictive measures against the entity concerned.

National Sanctions List

The NSL is maintained by the Ministry, which enters the entities into the NSL on the basis of a decision of the Government. The NSL will be publicly available on the website of the Ministry.

As of the day of the publication of the Sanctions Act in the Collection of Laws, the Government has not yet included any entity on the NSL.


The sanctioned entity is entitled to file an objection against its inclusion on the NSL to the Ministry. The Ministry shall submit the objection together with its opinion to the Government within 30 days of its receipt. The Government is subsequently obliged decide on the objection within 30 days from its submission.

In the event of a negative decision, the sanctioned entity may appeal against the Government’s decision to keep the entity on the NSL to a competent court. However, the appeal does not have a suspensive effect and the entity is considered a sanctioned entity until otherwise decided in the appellate proceedings.

The Sanctions Act is available in the Czech language here.


Kristína Doupal heads the Firm’s International Commercial & Trade Department in Prague, focusing on trade and commercial law matters. She advises clients in relation to a range of trade and commercial law issues, litigation and arbitration, as well as regulatory proceedings.


Martin Šupák is a member of the Prague Officeʼs practice groups focusing on pharmaceuticals & healthcare, compliance and capital markets.


Timoteus Hudcovic is an associate and a member of the Corporate and Mergers & Acquisitions Practice Groups in the Prague office.