The Center on European Union Law
Jean Monnet Center of Excellence for the Comparative Study of European Union Business Law at Fordham (EU-FORDHAM)

presents

Criminal Enforcement of Economic Sanctions in EU Law: New Strategies, Emerging Challenges, and the Limits of Criminalization

Wednesday, October 28, 2026
12:00 - 12:30 pm EST | check-in
12:30 - 1:50 pm EST | program

In-Person and on Zoom
Fordham Law School
Room 3-09 (Third Floor)
150 West 62nd Street
New York, NY 10023

CLE credit will be available.

About the Program:

Economic sanctions have become one of the European Union’s most prominent tools of external action, particularly since Russia’s invasion of Ukraine. Yet while restrictive measures are adopted at EU level, their implementation and enforcement continue to depend largely on national authorities and private economic actors. Against this fragmented background, the EU has recently taken a significant step further: violations and circumvention of EU sanctions have become an area of EU criminal law, accompanied by harmonized rules on corporate liability and an enhanced reliance on freezing and confiscation. This presentation asks whether turning to criminal law necessarily makes sanctions more effective. It examines the increasingly important role of corporations as gatekeepers of sanctions enforcement, the integration of sanctions compliance into corporate-liability frameworks, and the growing use of asset-recovery mechanisms. More broadly, it explores the tension between the foreign-policy objectives pursued through sanctions and the principles and safeguards that necessarily constrain criminal enforcement. The central argument is that criminal law may have an important role in addressing serious sanctions violations, but should not become the default remedy for shortcomings in sanctions implementation. A more differentiated combination of criminal, administrative, and compliance-based mechanisms may ultimately provide a more coherent, proportionate, and effective enforcement model.

Speaker:

Lorenzo Bernardini
Assistant Professor, European and Comparative Criminal Law, University of Southern Denmark

Commentator and Remarks:

Professor Thomas H. Lee
Leitner Family Professor of International Law, Fordham Law School (commentator)

Professor Martin Gelter
Professor of Law & Director of the Jean Monnet Center of Excellence, Fordham Law School (introductory remarks)

CLE Credit

CLE credit is approved in accordance with the requirements of the New York and New Jersey State CLE Boards for a maximum of 1.5 transitional and nontransitional professional practice credits.

ACKNOWLEDGEMENTS 

Co-funded by the European Union. Views and opinions expressed are however those of the author(s) only and do not necessarily reflect those of the European Union or the European Education and Culture Executive Agency (EACEA). Neither the European Union nor EACEA can be held responsible for them.