As EU restrictive measures continue to play a central role in the Union’s response to Russia’s war of aggression against Ukraine, businesses can expect increased scrutiny of sanctions compliance. Belgium has now taken the final step towards implementing Directive (EU) 2024/1226, introducing a more harmonised criminal enforcement framework for breaches of EU restrictive measures.

1. Why was Directive (EU) 2024/1226 adopted?

Directive (EU) 2024/1226 was adopted to ensure the effective enforcement of EU restrictive measures across all Member States. Until now, enforcement approaches varied significantly throughout the European Union. While some Member States already treated sanctions breaches as criminal offences, others relied on administrative enforcement. As a result, the consequences of violating EU sanctions often depended on the Member State concerned.

To address these inconsistencies, the Directive establishes a common framework of criminal offences and penalties for violations of EU restrictive measures. These restrictive measures include asset-freezing measures, prohibitions on making funds or economic resources available to designated persons, travel bans, sectoral economic and financial restrictions, and arms embargoes.

2. What changes under Belgian law?

At its plenary session of 9 July 2026, the Belgian Chamber of Representatives approved the legislation implementing Directive (EU) 2024/1226 into Belgian law. The new rules will enter into force on 1 September 2026.

Under the new framework, a wide range of sanctions-related conduct may constitute a criminal offence when committed intentionally or, in certain cases, through serious negligence. Examples include:

• Making funds or economic resources available, directly or indirectly, to or for the benefit of a designated person, entity or body;
• Failing to freeze funds or economic resources belonging to, owned, held or controlled by a designated person, entity or body;
• Facilitating the entry into or transit through the territory of a Member State of an individual subject to a travel ban.

The consequences of non-compliance can be significant. For individuals, violations are punishable by a prison sentence of more than three years and up to five years. Courts may also impose fines ranging from EUR 200 to EUR 2 million, which may be increased up to the equivalent value of the funds or economic resources involved. Companies can be held liable where sanctions violations are committed for their benefit by individuals holding a leading position within the organisation. Depending on the nature of the infringement, legal entities may face fines ranging from EUR 15,000 to EUR 150 million. It should be noted that the above fines are subject to the Belgian system of statutory surcharges, which currently multiply the amount of the fine by ten.

Lastly, the Belgian implementation of Directive (EU) 2024/1226 is not limited to the introduction of criminal offences and penalties. The Directive also requires the Belgian legislator to introduce rules on aggravating and mitigating circumstances, investigative powers, cooperation between national and European authorities, whistleblower protection, and reporting and data collection obligations. Taken together, these measures are intended to strengthen the effective enforcement of EU sanctions throughout the European Union.