EU Law and Practice Contributed by: Edward Borovikov, Laurens Engelen, Aurore Ancion and Semen Medvedkov, Dentons
Arguably, this update should make EU persons addi - tionally cautious about participating in possible cir - cumventing schemes. 7.3.2 Criminal Penalties Circumvention of sanctions is a criminal offence under EU law, with potential penalties including both crimi - nal and civil sanctions. Criminal penalties may involve substantial fines and significant imprisonment terms, with specific amounts and lengths varying by mem - ber state. Civil penalties can also include significant financial penalties, which similarly vary across mem - ber states.
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