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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.

Committee LIBERapporteur Sophia In 't Veld (Renew)
  1. Published in the Official Journal · 29 Apr 2024
  2. Signed · 24 Apr 2024
  3. Approval of the EP's first reading position by the Council (adoption of the legislative act) · 12 Apr 2024
  4. Discussions within the Council or its preparatory bodies · 5 Apr 2024
  5. 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.

Industry 2Civil society 3Public authorities, academia, other 1

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
Commission reference
COM(2022)684

How it got here

  1. Prop dir30 Jan 2023

Showing 6 of 6 submissions.

NR

Norwegian Refugee Council (NRC) EU

· · filed 30 Jan 2023 · source

PDF

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.

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CI

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.

LinkedInX
AA

Action against Hunger

· · filed 30 Jan 2023 · source

PDF

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.

LinkedInX
ES

European Savings and Retail Banking Group (ESBG)

· · filed 30 Jan 2023 · source

PDF

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.

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B

Bundesrechtsanwaltskammer

· · filed 30 Jan 2023 · source

PDF

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

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GB

German Bar Association

· · filed 27 Jan 2023 · source

PDF

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

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Take the dataCSV — all 6 submissionsJSONFull text, not the excerpt. Free to cite.Search every submission →

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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.