Májustól akár felszámolással is járhat az Oroszország elleni EU-szankciók megsértése
The European Union (EU) directive, adopted in April this year and to be implemented in Hungarian law by May 2025, obliges member states to introduce criminal and non-criminal measures in connection with sanctions imposed against Russia (and Belarus), including fines of up to 40 million euros for companies violating the sanctions, exclusion of the company from state subsidies and public procurement, and even liquidation of the offending company. Meanwhile, based on the current set of sanctions regulations, it is increasingly difficult to clearly assess under what conditions it is possible to establish or maintain business relations with partners operating in the affected country.
Although the EU sanctions against Russia have actually been in place since the Russian occupation of the Crimean Peninsula in 2014, the so-called sanctions packages known to the public are usually counted from the Russian invasion of Ukraine starting on February 22, 2022. By the end of June 2024, in less than two and a half years, no less than 14 sanctions packages had been adopted, often not a single legal provision or legal act, but one or more sets of rules. In addition, the EU has adopted new and new sanctions against Belarus, one of Russia’s important allies, which have followed the logic of the sanctions against Russia since the outbreak of the war.
The change is clearly illustrated by the fact that Regulation 833/2014/EU, which is one of the basic pillars of EU regulation, has expanded from 14 pages to 496 pages since its adoption in 2014, and this is only one piece of legislation in the EU sanctions area, knowledge of which is necessary, but not sufficient, for a Hungarian company to understand what EU sanctions currently mean for it.
Precise knowledge of the rules is also essential because the EU adopted a directive (2024/1226) in April this year, which prescribes penalties for violating the above-mentioned EU sanctions – these rules must also be implemented in Hungary by next May. Violation of the sanctions may in the future result, for example, in the liquidation of the offending company, a ban on it from carrying on business activities and a ban on state benefits, subsidies and public procurement. The directive also requires member states to impose fines on the offending company, the amount of which may reach EUR 40 million or 5 percent of the total global turnover achieved in the business year preceding the commission of the crime or the business year preceding the decision to impose the fine.
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