In France, unlike in other European countries, civil society cannot act as a civil party in cases of violations of European sanctions. In 2006, the government introduced a bill known as the “embargo” bill,23 which was intended to incorporate violations of European restrictive measures into the French Penal Code. Twenty years later, this now-outdated bill never made it to the Senate. In April 2024, Directive 122624 of the European Parliament and of the Council, which specifies the minimum penalties for violations of restrictive measures, required Member States to transpose this directive into national law within one year. As of now, the directive has still not been transposed into French law, even though the transposition deadline—May 20, 2025—has long since passed. Although a parliamentary commission was established in 2023 to evaluate the government’s policy on the export of military equipment,25 it has not yet produced any reports or held any public hearings. As the situation in Myanmar continues to deteriorate, the European Union’s restrictive measures against Myanmar were renewed at the end of April, with no new provisions added. This is baffling, especially given that so-called “crony” companies—such as Ky Tha—remain unsanctioned. But what this case demonstrates above all is the urgent need for France and the EU to wake up to the mechanisms for enforcing sanctions. If the European Union decides on sanctions, each member state is responsible for ensuring their compliance and effective implementation—a point that the French government seems to be deliberately ignoring in favor of its position as a shareholder in Thales and despite its diplomatic stances. We are calling ●​ Thales' unions and employees Submit large numbers of reports—which may be anonymous—through Thales’ internal platform, Thales Alert Lines, regarding violations of human rights and fundamental freedoms and compliance with trade regulations. Raise these issues with company leadership regarding sales to an authoritarian regime subject to European sanctions, specifically the Strategic and CSR Committee and the Risk Management Committee. 23 Embargoes and other restrictive measures | French Senate (2006, 21 February) Directive (EU) 2024/1226 of the European Parliament and of the Council on the definition of criminal offences and penalties for the violation of Union restrictive measures and amending Directive (EU) 2018/1673 | European Union law (2024, 24 April) 25 “The parliamentary committee tasked with reviewing the government’s policy on the export of military equipment has appointed Senator Cédric Perrin as its chair”, Press release | Senate (16 January 2025) 24

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