On October 11, 2016, the Court of Justice of the European Union ruled [3] in European Commission v. Italian Republic that Italy violated EU law “by failing to adopt all the measures necessary to guarantee the existence of a compensation scheme for victims of all violent intentional crimes committed on its territory.” According to the press release [4], Italy is obligated under Council Directive 2004/80/EC [5] to provide a general compensation scheme for the victims of violent, cross-border crimes. Italy contended that it was in compliance with the directive because member states were “merely required to enable EU citizens residing in another Member State to have access to the compensations systems already provided for in the legislation adopted in respect of their nationals.”  The Court, however, ruled that the member states’ provision must go further, requiring “that the principle of the prohibition of discrimination on the basis of nationality be observed as regards access to compensation” and also mandating “a national scheme guaranteeing a minimum level of fair and appropriate compensation.”