On March 25, 2025, the Spanish Council of Ministers approved a draft bill to implement Directive (EU) 2024/1226 on the definition of criminal offenses and penalties for the violation of Union restrictive measures and amending Directive (EU) 2018/1673 (âDraft Billâ and âDirectiveâ, respectively). The Directive established minimum Member State requirements concerning the definition of criminal offenses and penalties for the violation and circumvention of EU sanctions. For further detail on the Directive, see our blog post…
Financial institutions face an increasingly complex sanctions compliance environment. Sanctions are increasingly emerging at the forefront of compliance agendas given the proliferation of new restrictions and counter-measures, together with increasingly aggressive enforcement action extra-territorially. This is impacting both financial institutions and their clients, leading to expectations for more robust compliance programs for both. This has been acutely felt most recently in the Middle East following the USD 100 million sanctions fine against a Dubai based…