On 24 April 24 2024, the EU Parliament and the Council adopted Directive 1226/2024 which provides a framework for defining criminal offenses and the corresponding sanctions for breaching EU restrictive measures. The aim is to establish a set of minimum regulations regarding criminal offences for violating or circumventing these restrictive measures.

In this regard, Member States are required to identify actions that breach EU restrictive measures and to criminalize them. These behaviors are primarily outlined in the regulations that provide for sanctions against Russia, as well as in the activities related to the import and export of dual-use goods.

In this regard, the Directive requires Member States to implement effective, proportionate, and dissuasive sanctions for both natural persons (such as imprisonment or the withdrawal of permits and authorisations) and legal persons (through financial penalties).

Furthermore, the liability of legal persons could result in amendments to the Italian legislation on administrative liability for criminal offenses committed by legal persons, as per Legislative Decree 231/2001.

The Directive has come into effect on 19 May 2024, and Member States will have 1 year to implement it from that date.



In line with Regulation 833/2014, on 26 April the Italian National Authority (UAMA) released a communication outlining the process for submitting requests concerning intra-group transactions involving Russian companies under the control of EU companies.

Essentially, Article 5 n of Regulation 833/2014 imposes a prohibition on providing, selling, transferring, or exporting goods and services to the Russian government or legal persons, entities, or bodies established in Russia. This prohibition applies to a wide range of services, including accounting, auditing, architecture, engineering, legal consulting, IT, marketing services, and more.

Furthermore, the article includes an exception for intra-group services, whereby the prohibition does not apply to Russian companies that are owned or controlled by a company registered in an EU country (or a partner country such as Switzerland, the United States, Japan, the United Kingdom, South Korea, Australia, Canada, New Zealand, and Norway).

However, starting from 20 June 2024, authorization from UAMA will be required to provide such services even within the group.

In this regard, UAMA has published the technical communication indicating the procedures for submitting exemption requests according to Article 5 n, paragraph 10, letter h of Regulation 833/2014, available at the following link.


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