The end of 2025 marks a real turning point in the Romanian sanctions enforcement landscape, with the entry into force of the Law no. 224/2025 amending and supplementing the Governmental Emergency Ordinance no. 202/2008 on the implementation of international sanctions. Thus, the breaches that were previously treated as administrative offences are elevated to the level of criminal conduct. As of December 19, 2025, violations of international sanctions will carry criminal liability, reflecting Romania’s transposition of the EU Directive EU 2024/1226 on the definition of criminal offences and penalties for the violation of restrictive measures of the European Union (EU).
In this context, Law no. 224/2025 criminalized 12 distinct categories of acts that can be committed in relation to international sanctions imposed by the EU, including: making funds or economic resources available to persons or entities targeted by sanctions; non-compliance with the obligation to freeze the funds or economic resources of the entities concerned; allowing sanctioned persons to enter or transit through the territory of Romania; conducting or continuing transactions, including public procurement contracts or concessions, with sanctioned third countries or entities controlled by them; breaching restrictions on trade in goods and the provision of services (including financial, brokerage or technical support) to partners affected by the restrictions; circumventing sanctions by concealing funds or beneficial owners, providing false information or failing to report to the competent authorities; failure to comply with information obligations regarding frozen funds; as well as the violation of the conditions established by the authorizations issued by the competent authorities.
At a first reading of the new law, it is understood that only the violation of international sanctions imposed by the EU becomes a crime, although the scope of GEO 202/2008 (which is supplemented by the new law) also includes international sanctions established by United Nations Security Council’ resolutions or other non-binding international sanctions regimes, adopted within international organizations or by other states, to the extent that the Romanian authorities may consequently decide that they apply on the territory of Romania.
In the case of individuals, the sanction for committing these crimes in the standard version (the basic form of incrimination) is imprisonment from one to five years and the prohibition of exercising certain rights. However, the punishment limits are increased to two to seven years in prison if the funds or economic resources involved amount to at least 100,000 euros, in the equivalent of the national currency, at the time of the crime, or military or dual-use products are involved. The penalty increases to between five and 12 years, if the violation concerns military products in categories ML1 (Military List), ML2, ML3, ML4, ML6, ML9 and ML10. In the latter case or in the case of military or dual-use products, the act is criminalized even if it is committed by negligence, in which case the prison sentence limits are between six months and three years.
The attempt is also criminalized, with the exception of offences relating to non-compliance with the obligations to freeze the funds or economic resources of entities subject to sanctions, as well as acts of circumvention of EU international sanctions by failing to comply with the obligations to inform or provide information to the competent authorities. In addition to the risk of criminal liability, the consequences for the violation of sanctions can be serious even from the criminal investigation phase, given that Law no. 224/2025 imposes the obligation to take provisional measures, but also to confiscate assets, in accordance with the Criminal Code.
What level can the maximum fines for legal entities reach?
The legal person is criminally liable for the crimes provided for by Law no. 224/2025 and committed in the pursuit of its business activity or in its interest or on its behalf, by its management bodies, representatives or any other person acting under its authority. And it is very important to note that, in the event of the crime being committed by a legal person, Law no. 224/2025 provides for much higher values of the amount of a fine-day (which is the basis of the final fine) compared to those contained in the Criminal Code. Thus, art. 137 para. (2) of the Criminal Code provides that, in the case of a legal person, "the amount of the fine shall be established by the system of fine-days. The amount corresponding to a fine-day, between 100 and 5,000 lei, is multiplied by the number of fine-days, which is between 30 days and 600 days". On the other hand, Law no. 224/2025 derogates from these provisions and imposes amounts for fine-days that vary, depending on the crime actually committed, between 3,000 and 835,000 lei.
Thus, from a sanctioning perspective, committing any of the offences provided for under Law No. 244/2025 represents the most serious crime that a legal person may commit under the Romanian criminal law. For example, in the case of the crime of aggravated murder, according to the system of fine-days established by the Criminal Code, a legal entity could be sentenced to a criminal fine in the amount of 2,550,000 lei (5,000 lei x 510 fine days). On the other hand, according to Law no. 224/2025, if, for example, a legal entity violates the international sanctions imposed by the EU on military products of categories ML1, ML2, ML3, ML4, ML6, ML9 and ML10, it can be sanctioned with a criminal fine in the maximum amount of 281,400,000 lei (670,000 lei x 420 fine-days).
Similarly, in case of violation of the prohibition on making available to a person targeted by sanctions, an entity or a designated body or for their benefit of funds or economic resources, directly or indirectly, a legal person could be sanctioned with a criminal fine in the maximum amount of 200,400,000 lei (835,000 lei x 240 fine-days).
Moreover, if, for example, an economic operator violates by negligence the prohibition on selling, importing or transporting goods, if the prohibition or restriction of that behavior constitutes an EU international sanction, it can be sanctioned with a criminal fine in the maximum amount of 32,400,000 lei (35,000 lei x 240 fine-days).
In all cases, it is obvious that limits of the criminal fine provided by the Law no. 224/2025 for legal entities far exceed the general maximum of 3,000,000 lei imposed by the Criminal Code.
From the perspective of the competence to carry out the criminal investigation, Law no. 224/2025 assigns the investigation of these crimes to the exclusive competence of the Directorate for the Investigation of Organized Crime and Terrorism Crimes.
In conclusion, given the severity of the sanctioning regime, compliance with international sanctions becomes an essential element of governance and risk management. For this reason, economic operators must integrate the risk of sanctions into their internal control framework, by allocating adequate resources, implementing efficient processes for verifying customers and business partners and developing solid risk assessment and monitoring mechanisms regarding the type of transactions carried out.
