According to an official press release issued by the Government of Romania on 2 October 2025 [link], during the government meeting held on the same date, the Draft Law amending and supplementing Government Emergency Ordinance no. 202/2008 on the implementation of international sanctions, as well as amending and supplementing other normative acts (the “Draft Law”) was adopted [link]. The Draft Law will be submitted to the Parliament of Romania, with the request to be debated and approved under an emergency procedure.
An essential element of the Draft Law, as adopted by the Government of Romania, consists in the criminalization of the circumvention of international sanctions imposed by the European Union, in multiple forms expressly indicated in the draft. Thus, the criminal acts defined therein shall, if the Draft Law is adopted in its current form, be punishable by imprisonment ranging from 6 months to 12 years, respectively by the prohibition of certain rights.
Where the offenses are committed by legal entities capable of criminal liability, these shall be punished under the day-fine system, for which the Draft Law introduces certain aggravations compared to the general regime under the Romanian Criminal Code (i.e., a considerable increase in the standard limits of the value of a day-fine).
Certain of the acts criminalized under the Draft Law will also be punishable if committed by negligence. Likewise, attempt will also be punishable for certain offenses. At the same time, cooperation with state authorities by the offender, under certain circumstances and conditions, will be considered a mitigating circumstance. The acts could not represent criminal offenses if committed, under certain special conditions, for humanitarian assistance purposes.
From a procedural perspective, the Draft Law establishes the mandatory application of precautionary measures in cases involving such offenses, with the funds or economic resources involved being subject to confiscation. The competent authority for criminal investigation will be the Directorate for Investigating Organized Crime and Terrorism (DIICOT).
Lastly, the Draft Law specifies that individuals reporting violations of the legal provisions on the breach of the European Union’s international sanctions will benefit from the protection measures provided under Law no. 361/2022 on the protection of whistleblowers in the public interest.
Leroy și Asociații recommends, in light of the Romanian authorities’ current focus on ensuring full compliance with the European Union’s international sanctions framework, that all business relationships with potential risk of circumvention be subject to prior, careful, legal assessment — an area in which our lawyers have the necessary knowledge and experience to provide effective assistance.
