Overview
Croatia is an EU and UN member state which implements EU and UN sanctions. The Ministry of Foreign and European Affairs is responsible for sanctions in Croatia.
The Restrictive Measures Act 2023 provides for the implementation of international sanctions in Croatia. Under Article 7 of the 2023 Act, EU and UN sanctions immediately apply in Croatia. The 2023 Act divides responsibility for sanctions enforcement and licencing among several Ministries based on their areas of expertise. For example, the Ministry of Transport oversees sanctions measures targeting ships, aircraft, and trains.
Individuals who violate sanctions in Croatia can be sentenced to up to 5 years in prison or fined up to EUR 90,000.
Requests for additional information about sanctions in Croatia should be emailed to the Ministry of Foreign Affairs at sankcije@mvep.hr.
National Competent Authorities
The Ministry of Foreign and European Affairs (MFEA) is responsible for coordinating and monitoring sanctions and export controls in Croatia. It is also responsible for the implementation of EU Regulation 2021/821 on dual-use goods.
The competent authority for investigating breaches and issuing derogations / licences from sanctions depends on the asset caught by the restriction. These are listed at Article 12 of the Restrictive Measures Act (RMA) and include:
- The Ministry for Transport for ships, aircraft and trains;
- The Ministry of Internal Affairs for registered vehicles and civil arms;
- The Ministry of Justice for real property, business interests, and shares; and
- The Ministry of Finance for financial means.
The following ‘monitoring authorities’ are responsible for monitoring the implementation of restrictive measures under Article 13 of the Restrictive Measures Act (see above):
Legislation
Dual-Use Goods Control Act 2023
Ordinance on Application Forms for the Issuance of Licences for Dual-Use Items
Application form for licences to export or transfer dual-use goods
Application form for international import certificates and receipt certificates for dual-use goods
Sanctions Lists
EU sanctions are directly applicable in Croatia – EU Sanctions List.
Croatia also implements UN Sanctions – UN Sanctions Lists.
The Ministry of External and European Affairs publishes a regularly-updated consolidated list of individuals and entities subject to EU and UN sanctions, which is available here.
Licensing
The competent authority for licensing depends on the asset which the sanctioned person wishes to access or exchange. The full list of competent authorities is at Article 12 of the Restrictive Measures Act 2023.
Licensing requests related to financial assets should be addressed to the Ministry of Finance. Requests for licences related to real property and shares should be addressed to the Ministry of Justice. Requests for licences related to ships and aircraft should be addressed to the Ministry of Transport.
Enforcement
Penalties for sanctions and export control violations are set out in the Restrictive Measures Act (RMA) 2023 and the Dual-Use Goods Control Act (DUGCA) 2023.
Individuals and entities who violate sanctions can be fined or imprisoned for between 6 months and 5 years under Article 21 of the RMA. Possible fines for compliance failures and sanctions breaches range from EUR 600 to EUR 90,000 and are set out in full at Article 22 of MRA.
Monitoring authorities can also issue written warnings, temporary trade restrictions of up to 12 months and apply to courts for injunctions against businesses they consider are in violation of sanctions. The full extent of these powers is set out at Article 14 of RMA.
Individuals and entities who contravene EU or Croatian export control legislation in a manner that jeopardises Croatia’s compliance with international sanctions regimes can be imprisoned for up to 5 years under DUGCA. Less serious breaches of export control regulations will incur fines of between EUR 6,630 and EUR 66,360.
Reporting
EU reporting requirements apply in Croatia. These obligations are set out in Council Regulations and require natural and legal persons, entities and bodies to supply “any information which would facilitate the implementation [of sanctions]… to the competent authority of the Member State where they are resident or located.” See our EU Reporting page for more information.
Additional monitoring requirements for businesses are set out at Article 8 of the Restrictive Measures Act, which requires all natural and legal persons who implement sanctions measures to notify the Ministry of Foreign Affairs within 1 working day of implementation. Failure to do so is punishable by a fine or imprisonment.
Exporters of dual-use goods and services must notify the Ministry of Foreign and European Affairs within 15 days of the date of export and submit a copy of their permit and, if applicable, their single customs declaration. Full reporting requirements are set out at Article 15 of the Dual-Use Goods Control Act.
Export controls
EU export control provisions apply in Croatia. See our EU Export Controls page.
EU Regulation 2021/821, which relates to export controls on dual-use items, is implemented in Croatia by the Dual-Use Goods Control Act 2023. Croatia imposes an additional authorisation requirement under Article 5(2) of the Dual-Use Goods Control Act 2023, which requires export authorisation where the exporter has grounds to suspect that an item may be intended for a use set out in Article 4(1) of Regulation 2021/821.
Applications for export licences for dual-use goods should be submitted to the Ministry of Foreign and European Affairs as follows:
Ministry of Foreign and European Affairs
Directorate for Economic Affairs and Development Coordination
Export Control Division
Trg N. Š. Zrinskog 7-8
10000 Zagreb
Croatia
Tel.: +385 (0)1 4569 964
Fax: +385 (0)1 4551 795, +385 (0)1 4920 149
Email: ministarstvo@mvep.hr
Applications for export licences, provision of brokering services and technical assistance must be accompanied by the following documents:
- An original end-user certificate
- A copy of the operating licence or approval, if required
- A copy of documents stating the quality and technical characteristics of the goods in question
- An original or certified copy of the agreement concluded with the company importing the goods
Further guidance and copies of the relevant forms can be found here.