D.Lgs. 211/2025 – New Criminal Liability and Decree 231

Published 9 January 2026, Legislative Decree 30 December 2025, no. 211 enters into force 24 January 2026. Implementing Directive (EU) 2024/1226, the decree transforms administrative violations of EU restrictive measures into criminal offences with direct entity liability under Legislative Decree 231/2001.

• New Criminal Code offences (Articles 275-bis et seq.) target asset freezes, making funds available to designated entities, authorisation breaches, and gross negligence in dual-use classification. Extraterritorial reach covers Italian nationals abroad.
• Entity liability (Article 25-octies.2): 1-5% global turnover sanctions (min. €3-40M), 1-6 year disqualifications. Exemption requires updated 231 Models with CONSIS screening and dual-use protocols.
• Italian groups with China WFOEs, joint ventures and minority stakes: Chinese supply chains circumvent Russia sanctions (19 EU packages). Parent companies risk liability for subsidiary/participated entity violations if exercising direction or deriving benefit.

Actions: CONSIS screening, 231 Model update, training for China operations.