The EU Council has recognized the circumvention of anti-Russian sanctions as a criminal offense.

As explained by the EU Council, member states have different definitions of what constitutes a violation of sanctions and what punitive measures should be applied in this case. This may lead to varying degrees of sanction compliance and the risk of circumvention. Therefore, the inclusion of sanctions violations in the list of criminal offenses is the first of two steps aimed at ensuring the same degree of sanction application throughout the EU and prevent attempts to circumvent them. The next step will be the submission of a draft directive by the European Commission, which will contain rules establishing minimum compliance standards for defining criminal offenses and punishments for violating EU sanctions. The Council of the EU and the European Parliament must adopt this document.