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ARTICLE · 20 MARCH 2024

Teeth Can Bite: Towards Harmonized Rules On EU Sanctions Criminal Enforcement

Mayer Brown
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On March 12, 2023, the European Parliament ("EP") formally endorsed the adoption of a Directive defining criminal offences and penalties for the violation of European Union ("EU")...

European UnionInternational Law
Paulette Vander Schueren
Paulette Vander Schueren
Nikolay Mizulin
Nikolay Mizulin
Edouard Gergondet
Edouard Gergondet
Dylan Geraets
Dylan Geraets
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On March 12, 2023, the European Parliament ("EP") formally endorsed the adoption of a Directive defining criminal offences and penalties for the violation of European Union ("EU") restrictive measures, colloquially known as sanctions ("Directive").1 As a political agreement on the text of the Directive had already been reached by the EP and the Council of the European Union ("Council") on December 12, 2023, the formal adoption of the Directive is imminent and will likely lead to a new era for EU sanctions criminal enforcement.

EU sanctions enforcement is and will remain a Member State prerogative. The Directive will neither replace the EU's decentralized enforcement approach nor establish an EU-wide enforcement authority. The Directive, rather, seeks to address perceived issues linked to the unharmonized enforcement of EU sanctions by setting minimum requirements that will have to be observed by all Member States.

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