CZECH REPUBLIC Trends and Developments Contributed by: Jan Kohout and Illia Antonov, PRK Partners
Introduction: The Maturing Sanctions Landscape Four years into Russia’s full-scale invasion of Ukraine, the sanctions landscape in the Czech Republic has evolved from a state of initial shock and urgent adap - tation into a more mature, albeit still rapidly develop - ing, regulatory environment. The period between 2022 and 2024 was marked by a flurry of new and previ - ously unknown restrictive measures adopted at EU level, which required market participants, regulators and a wide range of direct and indirect addressees to recalibrate their operations almost overnight. While a degree of stability has now been achieved, the ongo - ing war of aggression and Russia’s increasingly hostile actions towards European countries make it difficult to envisage any development other than the continued strengthening of existing EU sanctions regimes and heightened pressure on combating the circumvention of adopted restrictive measures. The Czech Republic, a member state of both the United Nations and the European Union, initially was an active driver of EU sanctions policy, and more recently as a jurisdiction grappling with the practical complexities of enforcement, capacity constraints and the broadening reach of restrictive measures into sec - tors traditionally untouched by sanctions compliance. The Czech Republic’s role in EU sanctions policy: from architect to follower Between 2022 and 2025, the Czech Republic was an active and vocal participant in shaping EU sanctions policy towards Russia and Belarus. Czech diplomacy, led by the Ministry of Foreign Affairs (MFA), consist - ently pushed for ambitious restrictive measures at the European level, including the listing of additional individuals and entities. This proactive stance culmi - nated in the adoption of the so-called Czech “Magnit - sky Act”, which established an autonomous national sanctions regime. The national list was conceived as a bridging mechanism: it allows the Czech Govern - ment to sanction persons and entities proposed for EU-level listing until such listing is achieved through the consensus of all 27 member states. The political landscape, however, has shifted. Follow - ing the parliamentary elections in October 2025 and the formation of a new coalition government in early 2026, Czech foreign policy has undergone a discern -
ible recalibration. The new government’s position on Ukraine and sanctions has been described by com - mentators as more ambivalent than that of its pre - decessor, and the previous administration’s role as a driving force behind ambitious EU sanctions pack - ages appears to have given way to a more passive, follower-oriented posture. This shift carries practical implications. For business - es, it signals a period in which the impetus for new sanctions designations will likely originate primarily at the EU level rather than from Czech national initia - tives. Nevertheless, all existing EU sanctions pack - ages remain directly applicable and fully enforceable in the Czech Republic, and the trajectory of EU-level sanctions policy continues to point towards consoli - dation and reinforcement rather than relaxation. The national sanctions regime: a pragmatic innovation The Czech national sanctions list, maintained by the MFA and administered under the Sanctions Act, remains one of the more distinctive features of the domestic sanctions architecture. As of June 2026, the list contains twelve natural persons and three legal entities from several nations, including Russia, Leba - non and Georgia. Within recent years listed individuals notably included, alongside Russian nationals, Geor - gian law enforcement figures and a former Belaru - sian dissident who is understood to have become an accomplice of the Russian GRU military intelligence service. This illustrates the breadth of the govern - ment’s designating rationale. The national list operates on a straightforward prem - ise: when the MFA receives credible information that certain persons or entities have engaged in sanction - able conduct, it may propose their listing to the gov - ernment. If EU-level listing is not achieved within one month of the government’s decision (or immediately, in cases of urgency) the person or entity may be placed on the national sanctions list. Once the EU adopts its own listing, the national designation is cancelled. The procedure is not without safeguards; designated persons may submit reasoned objections to the MFA, with the government making the final decision, and judicial review available; though, neither remedy has suspensive effect. The national list represents a prag -
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