Italy has upgraded its enforcement regime for breaches of European Union restrictive measures, with Legislative Decree No. 211 of 30 December 2025 entering into force on 24 January 2026. The decree implements EU Directive 2024/1226, overhauls and broadens the criminal offences for violations of EU sanctions, replacing provisions of Legislative Decree 221/2017 that already criminalised such breaches, and for the first time makes companies liable for them under Legislative Decree 231/2001, exposing both individual executives and corporate entities to higher penalties than under the previous regime.
Under the new framework, corporate fines for the most serious sanctions violations are set on a sliding scale of between 1 per cent and 5 per cent of a company's total global annual turnover. Where a company's worldwide turnover cannot be determined — for instance, because adequate financial disclosures are not available — the maximum fine is fixed at €40 million. The previous corporate liability framework established by Legislative Decree 231/2001 had capped administrative corporate fines at €1,549,000.
COLLATERAL PENALTIES
The decree also introduces collateral sanctions beyond financial penalties. Convicted entities may face suspension of their operating licences, exclusion from public funding and government procurement processes, prohibition on advertising their products or services to the public, and, in the most serious cases, a ban on carrying on the business.
Outside negligent breaches involving military and dual-use goods, criminal liability under the decree requires proof of intent. The heightened criminal and financial-penalty exposure applies from 24 January 2026.
EU DIRECTIVE 2024/1226
EU Directive 2024/1226 required member states to introduce criminal sanctions for the most serious violations of EU restrictive measures.
Italy transposed the directive after the 20 May 2025 deadline set by the EU, with the decree signed on 30 December 2025 and entering into force on 24 January 2026.