Italy Imposes New Criminal Penalties for Violating EU Sanctions

This post explains Italy’s recent legal shift making breaches of EU international sanctions a criminal offence from 24 January 2026. It outlines what that means for businesses, directors and visitors — especially those who live, work or invest along the Italian Riviera.

I translate the technical changes of Legislative Decree No. 211 of 2025 into practical steps you can use. There is a focus on how coastal communities from Genoa to Sanremo might feel the effect.

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Italy criminalises EU sanctions breaches: the headline

On 9 January the decree was published in the Official Journal. It came into force on 24 January, after Italy missed the original EU transposition deadline.

The measure implements Directive (EU) 2024/1226 and turns actions that were previously administrative offences into criminal ones. The change updates the Italian criminal code by adding a specific chapter on crimes affecting the EU’s foreign and common security policy.

It replaces parts of the old Legislative Decree No. 109/2007 regime.

What this really changes

The new decree expands prosecutable conduct and tightens procedural rules. It brings corporate criminal liability squarely into play.

This increases legal risk for companies, employees and directors operating in Italy.

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Key elements to note include:

Criminalisation — Conduct previously punishable only by administrative penalties can now lead to criminal charges.

Corporate liability — Certain breaches are now predicate offences under Legislative Decree No. 231/2001, exposing companies to criminal responsibility.

Hefty corporate fines — Monetary penalties for corporations may reach up to 5% of global turnover, a startling exposure for international firms.

Procedural changes — Amendments to the Code of Criminal Procedure affect how investigations and prosecutions are conducted.

Whistleblowing reforms — Reporting channels and protections have been revised in connection with the new offences.

Terrorism-prevention alignment — The legal framework to fight terrorism has been adjusted to reflect the criminalisation of sanctions breaches.

Practical steps for businesses and visitors

Companies and directors need to move from awareness to action. Risk assessments, updated compliance systems and renewed training are now essential.

Individuals who travel to or do business in Italy should be aware that certain transactions may carry criminal exposure.

Immediate steps include updating internal controls and revising whistleblowing channels. Reviewing supply chains to ensure that no sanctioned persons, entities or transactions are involved is also important.

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Top recommendations

If you operate in Italy or plan to work with Italian partners, consider the following:

Audit your sanctions screening — Ensure lists, software and human checks are current and capture EU measures.

Update corporate policies — Embed sanctions compliance into 231-models and corporate governance documents.

Train staff and directors — Make sure decision-makers understand criminal exposure and reporting obligations.

Strengthen whistleblowing pathways — Align internal reporting with the revised protections and procedures.

Seek legal counsel — Specialist advice is crucial when potential predicate offences are on the table.

Why the Italian Riviera should care

The Italian Riviera is not immune to these national changes. The coastline’s economy depends on tourism, shipping, yachting and small-to-medium enterprises — all sectors that can be touched by sanctions rules.

From hotels and marinas to importers of luxury goods, the new criminal risks call for local vigilance. Communities from Genoa to the French border will feel the ripple effects in commercial contracts, banking relationships and cross-border services.

Local towns to watch and protect

Business owners, hoteliers and professionals in the following Riviera towns should prioritise compliance and legal readiness:

Genoa

Portofino

Santa Margherita Ligure

Rapallo

Camogli

Sestri Levante

Monterosso al Mare

Vernazza

Manarola

Riomaggiore

La Spezia

Sanremo

Here is the source article for this story: Italy Introduces New Criminal Penalties for Violating EU Restrictive Measures

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