Criminalising the Violation of EU Restrictive Measures: the New EU Proposal for a Directive on the Definition of Criminal Offences and Penalties for the Violation of Union Restrictive Measures

• Jurisdiction: European Union
• Year: 2025

Speaker

Lucia Zoli is a Legal and Policy Officer at the European Commission’s Directorate-General for Justice and Consumers (DG JUST), where she works within the Criminal Justice Unit. Her primary focus lies in the development of EU legislation on criminal justice, including her contributions to the ‘Freeze and Seize’ Task Force and the proposal for a Directive on criminal offences and penalties for the violation of Union restrictive measures.

From 2017 to 2022, Lucia served in the Legal Advice Unit of the European Anti-Fraud Office (OLAF), where she provided legal support on anti-fraud policy and investigations at the EU level.

Before joining the European institutions, she worked in a law firm specializing in economic and financial criminal law. Lucia holds a PhD in EU Criminal Law, with a research focus on the interplay between national and supranational criminal justice systems, reinforcing her deep expertise in cross-border enforcement and EU legal harmonization.

Topic

Lucia Zoli’s presentation at the ERA Annual Conference on White-Collar Crime in the EU 2023 explores the European Commission’s proposal for a Directive defining criminal offences and penalties for the violation of Union restrictive measures. In this EU-presentation, Zoli highlights how sanctions—such as asset freezes, trade bans, and entry prohibitions—are vital tools in promoting EU foreign and security policy objectives, yet their enforcement across Member States remains fragmented.

The presentation provides an overview of the two-step legislative process launched in 2022, beginning with the Council’s identification of sanctions violations as an EU crime under Article 83 TFEU, followed by the proposed Directive outlining harmonized criminal offences. These include failing to freeze assets, trading in prohibited goods or services, or providing unauthorized financial or legal assistance.

Zoli emphasizes legal safeguards such as the right to silence and legal...