1. Does Hungary have a sanctions regime in place?

Yes. UN sanctions and EU regulations are implemented on different levels: financial and asset-related restrictions as well as exclusions are covered by acts, trade restrictions and measures are regulated by government decrees

2. Does Hungary implement UN sanctions?


3. Does Hungary implement an autonomous sanctions regime?

Yes, national legislation is complementary to EU regulations. Act No. LII of 2017 on the Implementation of Financial and Asset-Related Restrictions Ordered by the EU and the UN Security Council dictates the procedure for dealing with persons and entities subject to such sanctions, whereas Gov. Decree No. 156/2017 on licensing the export, import, transfer and transit of military equipment and services and Gov. Decree No. 13/2011 on licensing international trade of dual-use products lay down detailed provisions on arms and dual-use products. Act LIII of 2017 on the Prevention and Combating of Money Laundering and Terrorist Financing and Act I of 2007 on the Admission and Residence of Persons with the Right of Free Movement and Residence also contain provisions related to sanctions.

4. What is the nature of the sanctions regime in Hungary?

The Hungarian sanctions regime is based on UN sanctions and directly effective EU Regulations. National legislation complements UN and EU sanctions.

5. Does Hungary maintain a list of sanctioned individuals and entities?

No, there is no separate list of sanctioned individuals and entities in Hungary other than that of EU regulations and UN resolutions.

6. Are there any other lists related to sanctions?


7. Does Hungary have a licensing or authorization system in place?

Yes. In relation to financial and asset related restrictions, the court may grant exemptions under section 12 of Act No. LII of 2017 and in relation to arms embargoes and dual-use products, the Authority of Defence Industry and Export Control of the Hungarian Trade Licensing Office may grant authorizations, provided conditions set forth in the sanctions are met.

8. What are the consequences for a breach of sanctions in Hungary?

A breach of sanctions may entail various criminal offenses in Hungary including: Criminal Offenses with Weapons Prohibited by International Convention; Violation of International Economic Restrictions; Failure to Report Violation of International Economic Restrictions; Criminal Offenses with Military Items and Services; and Criminal Offenses with Dual-Use Items. Possible criminal consequences include imprisonment, expulsion (deportation) and a fine.

9. Who are the relevant regulators in Hungary and what are their contact details?

For arms embargoes and dual-use products: Authority of Defence Industry and Export Controls of the Hungarian Trade Licencing Office T: (+36) 1 458 5578 F: (+36) 1 4585 885 E:

Defence Industry and Conventional Arms Trade Control Department T: (+36) 1 458 5588 F: (+36) 1 458 5885 E:

Export Control Department (for the export of items subject to international trade sanctions) T: (+36) 1 458 5599 F: (+36) 1 458 5869 E:

For financial and asset-related restrictions: National Tax and Customs Administration of Hungary Anti-Money Laundering Information Office T: (+36) 1 430 94 66 F: (+36) 1 430 93 05 E:

For prohibition of entry and stay: Immigration and Asylum Office T: (+36) 1 463 91 00 F: (+36) 1 463 91 08 E:

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Dr. Ildikó Szegedi Partner

Dr Kinga Mekler, Associate

Eversheds Sutherland

H-1026 Budapest,

Pasaréti út 59 (premises) H-1530 Budapest,

P.O. Box 23 (postal)


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