Regulatory & International Trade | RIT
Helping businesses clear legal regulatory hurdles in Europe
Regulatory & International Trade | RIT
Regulatory & International Trade | RIT
Helping businesses clear legal regulatory hurdles in Europe
EU Sanctions
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Italy is reshaping sanctions enforcement and corporate criminal liability

Two major legislative initiatives, currently under parliamentary review, will reshape the compliance landscape for companies operating in Italy:

  • The implementation of Directive (EU) 2024/1226 (Directive), introducing criminal offenses for breaches of EU restrictive measures and integrating them into the framework of corporate criminal liability
  • The comprehensive reform of Legislative Decree 231/2001 (231 Decree), aimed at revising the regime governing the liability of legal entities for crimes committed by their managers or employees in the interest or for the benefit of the company

Taken together, these developments will significantly change the Italian corporate compliance environment. On one side, compliance with international sanctions would become even more critical, not only because the scope of restrictive measures continues to expand but also because breaches may now trigger criminal liability for both individuals and companies. This also makes sanctions compliance a key component of any effective organizational model under the 231 Decree. On the other side, companies expect the upcoming reform of the 231 Decree to realign corporate criminal liability with international standards, enhancing its preventive and dissuasive function rather than its purely repressive dimension. As a result, the structure of organizational models, the role of [...]

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Quarterly Sanctions Update | Q3 2025

The third quarter of 2025 marks greater coordination between the European Union and United Kingdom on sanctions, specifically with respect to lowering the price cap on Russian oil, broadening the range of targeted individuals and entities, and introducing new measures against sanctions circumvention via third countries.

Key developments also include new sectoral restrictions, expanded export control powers, targeted guidance for high-risk industries and jurisdictions, and increased enforcement focus.

Beyond Russia, both the European Union and United Kingdom maintained pressure on Belarus, Iran, and Libya, with the UK also proscribing Palestine Action as a terrorist group.

In this update, our global team provides an in-depth look at key developments introduced between June and August 2025, highlighting what these changes mean for businesses across affected sectors.

Click here to read the full [...]

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Navigating EU Sanctions: How Investment Funds and Corporates Can Meet the ‘Best Efforts’ Standard

With the introduction of the 14th sanctions package, entities established in the European Union are required to ‘undertake their best efforts to ensure’ that non-EU subsidiaries they own or control do not undermine EU Regulation 833/2014 imposing EU sanctions against Russia, or EU Regulation 765/2006 imposing EU sanctions against Belarus. This obligation stretches to EU citizens, including those located outside the European Union, who control corporate and fund structures around the world.

The term ‘best efforts’ is not explicitly defined within the EU regulations. On November 22, 2024, the European Commission issued guidance on how to comply with this obligation in its Frequently Asked Questions on Russia sanctions (FAQ). The clarifications, however, largely reiterate obligations set out in the Preamble to the EU Regulation 2024/1745 which introduced the ‘best efforts’ requirement in June 2024.

In this alert, we summarize the key features of this provision, with a focus on how investment funds and other global corporates can meet the ‘best efforts’ standard. In response to the Commission’s overriding emphasis on awareness of one’s operations, existing structures and ongoing activities should be reviewed, and robust sanctions compliance policies should be put into place to efficiently navigate the increasingly turbulent EU sanctions [...]

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