The European Union’s 2024 Directive on Asset Recovery and Confiscation obliges Member States to, among other things, introduce legislative measures to enable the confiscation of “unexplained wealth”.

This policy paper examines this Article and the powers and restrictions that Member States will need to include in such “unexplained wealth” measures to ensure compliance with the Directive.

A recent judgment of the Court of Justice of the European Union (CJEU) addresses two significant weaknesses in the effectiveness of EU sanctions enforcement.

First, it makes it clear that an EU-wide ban on “brokering services” for military goods to or from Russia applies even when these goods do not physically enter EU territory.