On May 27, 2014, the Grand Chamber of the Court of Justice of the European Union (the Court) decided [3] (not yet available in English) the Zoran Spasic case, holding that the rule found in Title III, Chapter 3, of the Convention Implementing the Schengen Agreement [4] (CISA), which restricts the application of the ne bis in idem principle to cases in which the penalty imposed in a Member State has been enforced or is actually in the process of being enforced, is not contrary to the Charter of Fundamental Rights [5] of the European Union. According to the press release [6], the Court considered that “[t]he enforcement condition laid down in the CISA does not call into question the ne bis in idem principle as such, since its only purpose is to avoid a situation in which persons finally convicted in a Member State go unpunished.”