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…
Background The European Union continues to expand its sanctions regime against Russia and Belarus. The latest – the 18th – EU Russia/Belarus sanctions package was published on 19 July 2025, and included a range of additional sanctions, mainly targeting the Russian energy, banking and military industries, but also individuals and the Russian shadow fleet (see our previous blog post on the 18th sanctions package). EU sanctions against Russia are enacted in the form of regulations,…
On 20 May 2025, the European Union adopted its 17th sanctions package in response to Russia’s ongoing war against Ukraine. Building on the extensive measures already in place, this package signals a further tightening of economic and legal pressure points, with over 2,400 individuals and entities now sanctioned. Notably, the package reflects a growing willingness by the EU to extend its sanctions regime not only in scope but in geographic and sectoral reach. This blog…