Subscribe
A clearer and simpler guide to the 2025 reform and how businesses should respond
At the end of 2025, Italy introduced new rules that significantly change how companies must deal with European Union sanctions. The reform updates the law known as Decreto Legislativo 231/2001, which regulates when a company can be held responsible for certain crimes committed in its interest.
From now on, violations of EU sanctions are clearly included among the offenses that can trigger corporate liability. In simple words, if a company does business with people, companies or countries that are under European sanctions, it can face serious consequences.
What Are EU Sanctions?
EU sanctions are restrictions decided at European level to respond to international crises. They can include freezing assets, banning exports of certain goods, limiting financial transactions or prohibiting business relationships with specific individuals or entities.
Until now, breaking these rules was already illegal. But with the new reform, the responsibility of companies becomes more direct and the penalties potentially much heavier.
Heavier Fines, Bigger Risks
One of the most important changes concerns financial penalties. In the past, fines for companies under the 231 system were calculated using a fixed method. Now, in addition to that system, fines can also be based on a percentage of the company’s annual turnover.
This approach is similar to what already exists under the General Data Protection Regulation (GDPR), where large companies can receive very high fines. The idea is simple: the bigger the company, the bigger the potential penalty.
For businesses, this means that ignoring sanctions rules is no longer a secondary issue. The financial impact could be severe.
A European-Wide Change
The Italian reform follows a broader European decision: Directive (EU) 2024/1226. For the first time, all EU countries will apply similar rules and similar penalties for sanctions violations.
In the past, there were differences between Member States. Some were stricter, others less so. This created uncertainty for companies operating in more than one country. Now the system is more uniform, which makes the rules clearer across Europe.
This harmonization is good news for companies that work internationally. However, it also means that enforcement will likely become more consistent and stricter everywhere.
Companies Must Check More Carefully
The new system gives companies a much more active role. Businesses are now expected to carefully check who they are dealing with before signing contracts or shipping goods.
This means verifying:
Who the customer is
Who the supplier is
Where the goods are going
How payments are made
Companies must ensure that none of these elements involve individuals, organizations or countries subject to EU sanctions.
To help with this, the European Union provides an official online tool called the EU Sanctions Map. It allows anyone to see updated lists of sanctioned countries, people and sectors.
But simply consulting the website is not enough. Companies need to build internal procedures to check transactions regularly and document the controls they perform.
The Practical Impact on Businesses
For many companies, especially small and medium-sized ones, this reform may feel like a heavy burden.
They may need to:
Update their internal rules and codes of conduct
Review their risk assessments
Introduce clearer procedures before approving international deals
Keep records of all checks performed
In addition, contracts with customers and suppliers should include clauses requiring compliance with EU sanctions. Companies should also reserve the right to immediately terminate a contract if sanctions are violated.
Another key element is training. Employees working in sales, logistics, purchasing, finance and management must understand the risks. They should know how to recognize warning signs and what to do if something seems suspicious.
The Risk of Doing Too Much
While the reform aims to strengthen compliance, there is also a risk that companies may become overly cautious. Fear of penalties could lead businesses to block legitimate transactions simply because they appear complex or risky.
This “over-compliance” could slow down trade and reduce competitiveness, especially compared to companies outside the EU that are not subject to the same strict obligations.
For smaller firms, the cost of new software, consultants and training programs may also be significant.
Finding the Right Balance
The reform clearly sends a message: EU sanctions are not just political decisions, but rules that companies must actively enforce in their daily operations.
At the same time, the harmonized European framework reduces confusion and creates a single standard across Member States. This can help companies design clearer and more consistent compliance systems.
The challenge now is balance. Businesses must take sanctions seriously, organize internal controls and train their staff. But they must also avoid unnecessary fear and excessive bureaucracy.
In the coming months, companies that act early — updating procedures, informing employees and strengthening internal checks — will be better prepared. The new rules are demanding, but with the right approach, they can be managed without paralyzing business activity.
For Italian companies, the message is simple: know who you are working with, document your checks, and treat sanctions compliance as a core part of doing business in today’s global economy.
Alessandro Fiorentino