site.btaGovernment Approves Bill Making Violations of EU Restrictive Measures Serious Crimes

The Government on Thursday approved a bill that would make violations and circumvention of EU restrictive measures serious criminal offences.

The offences would be punishable by imprisonment, substantial fines and, where applicable, deprivation of certain rights.

The amendments would fully transpose Directive (EU) 2024/1226 of the European Parliament and of the Council of April 24, 2024, on the definition of criminal offences and penalties for the violation of Union restrictive measures and amending Directive (EU) 2018/1673. The transposition deadline expired on May 20, 2025, and the European Commission has opened an infringement procedure against Bulgaria.

The bill would add a chapter to the Penal Code entitled “Crimes against European Union Restrictive Measures”. The new offences would include violations of measures freezing funds or economic resources and restrictions on the entry of designated persons into Member States, commonly known as travel bans.

The bill would also criminalize violations of prohibitions or restrictions on concluding or continuing transactions of any kind, including public procurement and concession contracts. Other offences would cover breaches of bans on providing financial services or carrying out financial activities, such as financing, financial assistance, investments, investment services and deposit-taking.

The provision of non-financial services in violation of EU restrictive measures, including legal advisory, trust, accounting and auditing services, would also be criminalized.

Circumvention of EU restrictive measures would constitute a separate offence. One example would be sanctioned individuals or companies transferring funds or economic resources they own to third parties.

Using an option provided by the Directive, the bill sets a threshold of EUR 10,000. Violations involving funds, economic resources, goods or transactions below that amount would not constitute criminal offences.

Providing humanitarian assistance to people in need in accordance with the principles of impartiality, humanity, neutrality and independence would not constitute a criminal offence.

Lawyers defending or representing clients in criminal, civil or administrative proceedings would also be exempt, including when providing legal advice on instituting or avoiding such proceedings.