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On 25 July 2025, Cyprus enacted the Criminalization of Violation of Union Restrictive Measures Law of 2025 (Law 149(I)/2025), introducing criminal penalties for breaches of EU restrictive measures and fully transposing Directive (EU) 2024/1226 into Cypriot law.
The Law 149(I)/2025 implements the EU Directive on criminal offences for breaches of restrictive measures and establishes a strengthened domestic criminal framework to detect and punish sanctions evasion and circumvention. The Law applies to both natural and legal persons and is designed to ensure Cyprus meets its EU enforcement obligations.
The law defines a detailed list of offences that constitute breaches of EU restrictive measures, including:
- Making funds or economic resources available to designated individuals or entities.
- Failing to freeze assets that are subject to EU sanctions.
- Facilitating the travel of sanctioned persons within EU territory
- Concealing the ownership or control of assets linked to sanctioned parties.
- Engaging in transactions designed to circumvent restrictive measures.
Conducting trade or financial dealings with designated persons in breach of EU rules.
Penalties under the New Regime
For individuals: Fines of up to €100,000; and/or imprisonment for up to five years, depending on the gravity of the offence.
For legal entities: Fines of up to €40 million or 5% of global turnover, whichever is higher.
Additional sanctions may include:
- Revocation of operating licences.
- Exclusion from public procurement or funding opportunities.
Prohibitions on engaging in specified business activities.
Exemptions: Activities providing humanitarian aid or addressing essential human needs are excluded from criminal liability, ensuring that legitimate aid operations remain protected.
The Law requires close collaboration between Cypriot authorities and their EU counterparts. Enforcement agencies must work together with other member states, Eurojust, Europol, and the European Public Prosecutor's Office (EPPO) to ensure sanctions are applied consistently and violations are effectively prosecuted.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
