European Union

Global sanctions guide

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  1. Does the EU have a sanctions regime in place?

Yes.

  1. Does the EU implement UN sanctions?

Yes. The EU implements sanctions adopted by UN Security Council.

  1. Does the EU implement an autonomous sanctions regime?

Yes. In addition to UN sanctions, the EU implements autonomous sanctions or EU additions to UN sanctions in line with the stated objectives of the EU’s Common Foreign and Security Policy (“CFSP”).

  1. What is the nature of the sanctions regime in the EU?

EU sanctions comprise both economic and non-economic sanctions. The EU Council imposes restrictive measures within the framework of the CFSP. The Council first adopts an CFSP Decision under Article 29 of the TEU. The measures foreseen in that Council Decision are either implemented at EU level (by way of Regulation) or at national level.

Measures such as arms embargoes or travel restrictions are implemented directly by member states, which must act in conformity with CFSP Council Decisions. Other measures, such as freezing funds, are implemented by way of Regulation, adopted by the Council, on a joint proposal from the Commission and the High Representative of the Union for Foreign Affairs and Security Policy under Article 215 of the TFEU.

The European Parliament must be informed of any such Regulations. Regulations are binding and directly effective throughout the EU. Both Regulations and Council Decisions are subject to judicial review by the Court of Justice and the General Court in Luxembourg.

Restrictive measures must respect the EU’s international obligations and those of its member states, in particular World Trade Organisation agreements.

  1. Does the EU maintain a list of sanctioned individuals and entities?

Yes. The EU’s consolidated list is available at:
www.eeas.europa.eu/cfsp/sanctions/consol-list/index_en.htm

  1. Are there any other lists related to sanctions?

No.

  1. Does the EU have a licensing or authorisation system in place?

Yes. The licensing/authorisation system is however dependent on the internal licensing systems in place in each EU member state, as each EU member state is responsible for regulating the practical aspects of EU sanctions, including enforcement, into their national law.

Therefore, in order to obtain further details on the licensing or authorisation system in place in a particular EU jurisdiction, the regulator of the EU member state in question should be contacted in the first instance.

  1. What are the consequences for a breach of sanctions in the EU?

The penalties for any breach of EU sanctions are dependent on the national legislation of EU member states.

  1. Who are the relevant regulators in the EU and what are their contact details?

As individual EU member states are responsible for the practical implementation of EU sanctions within their respective countries, the internal regulators of the relevant EU member state should be contacted in the first instance. Details of the regulators may be found in the annexes to the relevant EU Regulation which details the restrictive measure/sanctions policy in question.

Alternatively, you may contact the Commission at: relex-sanctions@ec.europa.eu, who will contact the regulator within the relevant EU Member State on your behalf.

Contributor law firm

Natalie Limbasan, Eversheds, 8 Place D'Iéna, Paris, 75116, France