FRANCE Law and Practice Contributed by: William Julié, Amélie Beauchemin and Camille Gosson, WJ Avocats
• withdrawal of permits and authorisations to pur - sue activities that resulted in the relevant criminal offence; • placement under judicial supervision; • judicial winding-up; • closure of establishments used for committing the criminal offence; and • where there is a public interest, publication of all or part of the judicial decision relating to the criminal offence committed and the penalties or measures imposed, without prejudice to rules on privacy and the protection of personal data. The Directive provides for minimum fines, depending on the offence committed. The Directive was imple - mented in France through Decree No 2025-470 of 28 May 2025, which gave competence to the Advisory Board on Combating Money Laundering and Terrorist Financing to ensure co-ordination and co-operation between law enforcement agencies and the authori - ties responsible for implementing EU restrictive meas - ures (Article D561-51 of the Monetary and Financial Code). As explained above, given that criminal pen - alties for sanctions violations were already in effect under French law, the transposition of the Directive did not bring any substantial changes at regulatory level. The creation of criminal offences and the deter - mination of applicable penalties fall within the field reserved to the legislature under Article 34 of the Con - stitution and therefore require transposition by statute; a bill to that effect is currently pending before Parlia - ment (see 3.1 Significant Court Decisions or Legal Developments ). 2.2.3 Civil Enforcement Action As detailed above, there is no civil enforcement in France. The Autorité de contrôle prudentiel et de réso- lution (ACPR) exercises administrative enforcement over entities under its supervision, such as banks, insurers and asset managers, especially regarding asset-freeze obligations under UN and EU restrictive measures. 2.2.4 Criminal Enforcement Action Examples of key criminal enforcement actions in respect of sanctions breaches in France in the last few years include:
• the Lafarge trial, which related to the financing of ISIS in breach of EU and UN sanctions – in October 2024, the Paris court ordered the trial of Lafarge and eight former executives for alleged ter - rorist financing activities; • the Baltic Leader trial – in July 2024, the Rouen Prosecutor sought EUR8 million in fines, confisca - tion of a vessel and a ten-month suspended prison sentence against a captain accused of breach - ing Russian sanctions by departing Rouen with a Russian-flagged vessel controlled by a sanctioned bank; the captain was subsequently acquitted on all charges; and • the issuance in April 2025 – by the French media regulator Arcom – of an order to Eutelsat to cease the broadcasting of two channels owned or con - trolled by JSC National Media Group, which is a designated person under the EU’s Russian sanc - tions. More generally, since 2022, several criminal investiga - tions have been launched in France against Russian oligarchs for circumventing EU sanctions, primar - ily involving money laundering, tax fraud and asset concealment. In March 2024, proceedings targeted Ruslan Goryukhin and Mikhail Opengeym, accused of hiding over EUR70 million in real estate through offshore structures. In 2022, Igor Sechin became the subject of an investigation after his yacht was seized in La Ciotat for attempting to evade asset freezing measures. In 2023, Alexey Kuzmichev was indicted in Paris for aggravated tax fraud and sanctions vio - lations. Assets linked to Artur Ocheretny and Iekat - erina Solotsinskaya were also seized in the Basque Country and Paris in similar cases. Since 2023, the French National Financial Prosecutor’s Office and the anti-organised crime unit (Junalco) have intensified their investigative activities targeting individuals and entities under EU sanctions. 2.2.5 Mitigation Article 132-78 of the French Criminal Code provides for two mitigating circumstances that are applica - ble only to certain offences, when provided by law, namely: • an individual who attempted to instigate an offence but alerted the administrative or judicial authorities,
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