This past July, Cyprus has enacted Law 149(I)/2025, on the criminalization of the violation of the restrictive measures of the European Union (the “Law”).
The Law marks a pivotal step establishing a clear criminal framework for enforcing European Union (“EU”) sanctions in line with Directive 2024/1226. The Law criminalizes key sanctions breaches, including but not limited to the provision of funds to designated persons, the failure to freeze assets of such persons, the execution of prohibited transactions, and the circumvention of restrictions, with certain offences involving dual-use or military goods being punishable even through gross negligence.
The Law applies to both individuals and companies, with penalties reaching five years’ imprisonment or EUR 100,000 for natural persons, and up to 5% of global turnover or EUR 40 million for legal entities, along with potential license revocations and business restrictions.
Enhanced enforcement powers, asset-freezing measures, cooperation with EU bodies, the establishment of a National Sanctions Implementation Unit, and expanded whistleblower protections collectively strengthen Cyprus’ commitment to fully aligning with the EU sanctions regime.
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For more information, please reach out to Kyriaki Stinga, Adonis Zachariou and Maria Vyronos.
