Croatia
1. Does Croatia have a sanctions regime in place?
Yes.
2. Does Croatia implement UN sanctions?
Yes.
3. Does Croatia implement an autonomous sanctions regime?
No.
4. What is the nature of the sanctions regime in Croatia?
Croatia follows the international restrictive measures laid down in legal acts of the UN, the EU and other international organizations which are binding for Croatia, and restrictions or obligations introduced by Croatia in another manner, in line with international law or the law of the EU. Restrictive measures may be as follows: a) termination of diplomatic relations; b) total or partial termination of economic relations; c) total or partial restriction of import, export, transit, provision of services, and of transport, mail and other communications; d) arms embargo; e) restriction on entry into the country; f) restriction on disposal of assets (freezing of assets); and g) other measures in line with international law.
5. Does Croatia maintain a list of sanctioned individuals and entities?
Croatia uses the EU or international lists regarding sanctions.
6. Are there any other lists related to sanctions?
Yes. The Ministry of Foreign Affairs maintains a database on sanctions measures enforced by Croatia.
7. Does Croatia have a licensing or authorization system in place?
According to the Act on International Restrictive Measures (official gazette 139/2008, 41/2014, 63/2019 hereinafter referred to as: the “Act”) in cases when a restriction on disposal of the assets has been imposed towards a financial institutions incorporated in the countries that are subject to restrictive measures, the approval of the Ministry of Finance may be obtained for the authorization of such financial transactions.
8. What are the consequences for a breach of sanctions in Croatia?
Breach of the following restrictive measures shall be punished by a monetary fine or prison sentence from six months to five years: breach of total or partial restriction of import, export, transit, provision of services and of transport, mail and other communications and arms embargo. For breach of the other restrictive measures listed above at paragraph 4, the perpetrator can be punished by a fine or prison sentence of up to three years. Any breach that is due to negligence (i.e. the breach is not intended) shall be punished by a fine or prison sentence of up to six months.
9. Who are the relevant regulators in Croatia and what are their contact details?
Ministry of Foreign and European Affairs Trg N. Š. Zrinskog 7-8, 10000 Zagreb Croatia T: (+385) 1 4569 964 F: (+385) 1 4551 795 E: kabinet.ministrice@mvep.hr www.mvep.hr/en/
Contributor law firm
Ivan Ivković
Senior Associate
Savoric & Partners,
Ilica 1/A, 14th Floor,
Neboder,
HR-10000 Zagreb,
Croatia
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