With Legislative Decree No. 211/2025, published in the Official Gazette on 9 January 2026 and implementing Directive (EU) 2024/1226, the sanctions framework governing EU restrictive measures has been comprehensively redesigned, with immediate implications for corporate compliance and Legislative Decree 231/2001. The new regime strengthens oversight of cross-border operations, financial flows, authorisation requirements, and the traceability of decision-making, requiring companies to adopt a more structured and well-documented approach.

Benedetta Cantelli revisits the issue in an article published in Diritto & Affari: the legislative reform broadens the criminal relevance of conduct involving both violations and circumvention, and affects Legislative Decree 231/2001 through the introduction of new predicate offences (Article 25-octies.2) and a sanctions model calibrated, inter alia, to global annual turnover. This is accompanied by the extension of whistleblowing protections to reports concerning breaches of EU restrictive measures, with direct consequences for internal policies, report management, and training.