GLITSS

WG3 – Circumvention of EU sanctions and illicit trade: What is the role of criminal enforcement?

The talk by Dr Lorenzo Bernardini and Francesca Finelli from the University of Luxembourg addresses the recent developments of the EU sanctioning practice in the context of Russia‚Äôs aggression on Ukraine, illustrating the enforcement strategies adopted by the Union, since February 2022, to counter circumvention. Focusing on the phenomenon of sanctions evasion, this talk highlights its interconnections with illicit trade and illicit money flows. The talk ends by discussing critical remarks on the recent reform criminalising sanction breaches, questioning the role of criminal law in the field, as well as the Commission’s initiatives on asset recovery and confiscation.

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