Breaking EU sanctions is a crime: Italian firms take action

Context

In brief

• From January 24, 2026, violating EU sanctions is a crime in Italy
• Up to 6 years imprisonment for individuals
• Fines up to 5% of turnover for companies

Key facts

• What: New decree criminalizing violations of EU sanctions
• When: Effective from January 24, 2026
• Where: Italy
• Who: Italian companies with suppliers, customers, or partners in countries subject to EU restrictive measures
• Amount: Fines up to 5% of global annual turnover

From January 24, 2026, violating the economic sanctions imposed by the European Union will come at a high cost: with the entry into force of the new decree, in Italy it will be considered a criminal offense, with penalties of up to six years imprisonment for individuals and fines calculated on the global turnover for companies. Three months after the entry into force of the new regulatory framework, many companies, especially the smaller ones, are only now discovering that they may be potentially exposed.

The DLgs 211/2025 transposed Directive EU 2024/1226, born out of the need to make the sanctions imposed on Europe after the Russian invasion of Ukraine in 2022 truly effective. The problem was simple: each Member State applied the restrictive measures differently, with consequent 'grey areas' that allowed for triangulation and evasive operations. Hence the European push to criminalize violations in a uniform manner.

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Operational details

Analysis of the implications for cross-border workers

The new EU sanctions regulations can have a significant impact on cross-border workers who work in Italy and reside in Switzerland. In particular, Italian companies operating with suppliers or customers in countries subject to EU restrictive measures must be particularly careful not to violate the new provisions.

Comparison with the previous situation

Before the entry into force of the new decree, violations of EU sanctions were considered mainly as administrative offenses, with limited pecuniary sanctions. Now, with the introduction of criminal liability for negligence, companies must be much more careful in monitoring their operations and complying with the restrictive measures imposed by the EU.

Concrete scenarios

A concrete example is represented by an Italian company operating with suppliers in Russia or Belarus. If the company does not promptly block the funds of an entity included in the sanctions lists, it can incur criminal and administrative sanctions. It is therefore fundamental for companies to adopt rigorous control procedures and update their compliance models.

Implications for cross-border workers

For cross-border workers who work in Italy and reside in Switzerland, it is important to be aware of the new regulations and the possible implications for the companies they collaborate with. In particular, it is crucial to verify that Italian companies comply with the new provisions to avoid sanctions and criminal proceedings.

For further information and to check their tax situation, cross-border workers can use the source tax calculator.

Useful tools to protect your net income

To reduce FX leakage, compare CHF-EUR exchange options and banks for cross-border workers.

Key points

Concrete actions for businesses

Italian companies must adopt a series of concrete measures to comply with the new regulations. First and foremost, it is essential to update compliance models to include the new provisions on EU sanctions. This can be done with the help of specialized legal consultants.

Step-by-step procedure

1. Risk assessment: Companies must assess their exposure to the risk of violating EU sanctions. This can be done through an internal analysis or with the help of external consultants. 2. Updating compliance models: Companies must update their compliance models to include the new provisions on EU sanctions. This may include introducing new control procedures and training staff. 3. Continuous monitoring: Companies must continuously monitor their operations to ensure compliance with EU restrictive measures. This can be done through the use of monitoring tools and constant updates of the sanctions lists. 4. Staff training: Companies must train their staff on the new regulations and control procedures. This can be done through training courses and seminars. 5. Periodic verification: Companies must periodically verify their compliance with the new regulations. This can be done through internal or external audits.

Useful tools

To help companies comply with the new regulations, several tools are available. For example, the sanctions risk calculator can help companies assess their risk exposure and adopt the necessary measures to prevent violations.

Final CTA

For more information and to check their tax situation, companies can use the withholding tax calculator.

Source: varesenews.it