On 23 January 2026, the European Commission released new FAQ guidance providing clarifications for operators navigating the EU’s expanding Russia sanctions framework. Notably, the European Commission updated their Consolidated FAQs on Sanctions against Russia and Belarus (the “FAQs”, accessible here) with guidance on the Nord Stream transaction ban and the EU’s 19th sanctions package, summarized below. I. Clarifications on the Nord Stream Transaction Ban (Article 5af, Regulation 833/2014) The EU has published dedicated FAQs interpreting…
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 November 12, 2025, Canada announced further amendments to the Special Economic Measures (Russia) Regulations (the Regulations). These amendments list an additional 13 individuals and 11 entities under Schedule 1 of the Regulations and took effect on November 6, 2025. These newly listed entities and individuals are stated to enable Russia’s energy sector and hybrid warfare strategies, including suppliers of cyber infrastructure and companies linked to liquefied natural gas operations that help finance military activities.…
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…