Penalties for breaching sanctions: what Directive 2024/1226 introduced

The date it starts to bite

Member States had to bring implementing rules into force by 20 May 2025 (Article 20 of the directive). The Commission opened proceedings against several States that missed the deadline, which itself says how high the topic sits.

Penalties for individuals

For breaches concerning goods, services, transactions or activities worth at least EUR 100 000, the maximum term of imprisonment must be at least five years. For certain offences involving frozen funds at the same value the threshold is five years, and for another category at least one year. For circumvention in the form described in Article 3(1)(c) the threshold is at least three years.

These are thresholds for the maximum, not penalties applied automatically. A State may go higher, it may not go lower.

Fines for companies

For legal persons the maximum fine may not be lower than 5 percent of total worldwide turnover in the year preceding the offence or the year preceding the fining decision, or EUR 40 000 000. For the lighter category of offences the thresholds are 1 percent of turnover or EUR 8 000 000.

The reference point is the worldwide turnover of the group, not the revenue from the transaction that breached the ban. For a company with a few hundred million in turnover that means a fine counted in millions for a single shipment.

What it changes for an exporter

The directive criminalises, among other things, circumvention of prohibitions, failure to provide information to authorities and breach of the conditions of an authorisation. The burden in proceedings shifts to documentation: who checked, when, and against which wording of the provision.

The practical conclusion is uncomfortable but simple. A check without a record does not protect you, because it does not exist in the case file. That is why a dated proof of check naming the version of the act stopped being an auditor formality and became part of the defence.

Questions fréquentes

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