NRC strongly welcomes the inclusion a humanitarian carveout within the proposal, which excludes humanitarian aid from the risk of criminalization under the new Directive. Its reference in the operative paragraphs, and not only in the memorandum is particularly commended as it would give direct effect to the exemption.
2022/0398(COD) · In Force
Definition of criminal offences and penalties for the violation of Union restrictive measures
6 submissions from 6 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 84 submissions on this file. Shown here: the 6 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
- Published in the Official Journal · 29 Apr 2024
- Signed · 24 Apr 2024
- Approval of the EP's first reading position by the Council (adoption of the legislative act) · 12 Apr 2024
- Discussions within the Council or its preparatory bodies · 5 Apr 2024
- Discussions within the Council or its preparatory bodies · 3 Apr 2024
Who showed up
2 submissions from industry — companies and their trade associations — against 3 from civil society: NGOs, consumer organizations, environmental groups and trade unions.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
The file, right now
The consultation closed on 30 Jan 2023 — it ran from 5 Dec 2022.
- Policy area
- Justice (DG JUST)
- Where it stands
- Awaiting adoption
- Legislative stage
- In Force
- Lead committee
- LIBE
- Rapporteur
- Sophia In 't Veld (Renew)
- Procedure
- 2022/0398(COD)
- Commission reference
- COM(2022)684
How it got here
- Prop dir30 Jan 2023
Showing 6 of 6 submissions.
CARE International AISBL
· · filed 30 Jan 2023 · source
In general, it is crucial to swiftly and effectively ensure the full operationalization of the UNSC Resolution 2664 from 9 December 2022 (S/RES/2664(2022) by which the UNSC adopted a standing humanitarian exemption to nearly all its asset freeze sanctions regimes. In practice, the effectiveness of the carveout will now depend on swift and effective national implementation by key States and the EU.
Action against Hunger recommends to swiftly and effectively ensure the full operationalization of the United Nations Security Council (UNSC) Resolution 2664 from 9 December 2022 (S/RES/2664(2022) by which the UNSC adopted a standing humanitarian exemption to nearly all its asset freeze sanctions regimes.
The European Savings and Retail Banking Group (ESBG) welcomes the initiative to harmonize the definitions of criminal offences and penalties for the violation of EU restrictive measures. We believe it would ensure a more consistent enforcement of restrictive measures between EU Member States, even if this enforcement is not centralized at EU level.
The German Federal Bar Association is an umbrella organisation for lawyers and their associations. It represents the interests of the 28 bar associations, and thus of the entire Bar of the Federal Republic of Germany, with around 166.000 lawyers vis-à-vis authorities, courts and organisations at national, European and international level. See attached opinion
Filed in German · English published by the European Commission
DEAR Madam or Sir, please find attached the position paper (in German) of the German Bar Association on the proposal for a directive on the definition of criminal offences and penalties for the violation of Union restrictive measures. Child regards, [name removed]
Filed in German · English published by the European Commission
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.