The Council of the European Union recently published a revised version of the EU Best Practices for the effective implementation of restrictive measures. The guidance it contains provides some clarification of the many issues which arise in practice for both Member States and for persons and entities subject to sanctions or otherwise affected by their application. Significant uncertainties in the interpretation of EU sanctions do, however, remain.
Our briefing identifies the main amendments, which appear to envisage an increasing role for the private sector in the implementation of restrictive measures.
Key contacts
Andrew Cannon
Partner, Head of International Arbitration, London, Paris, India Group, Nordic Group, Africa Group, Kazakhstan Group, Ukraine Group and Central Asia Group
Christian Leathley
Partner, Head of International Arbitration, US, London, New York and Latin America Group
Dr Patricia Nacimiento
Partner, Germany, Central Asia Group, Kazakhstan Group, Latin America Group and Ukraine Group
Amal Bouchenaki
Partner, New York, Latin America Group and Africa Group
Laurence Franc-Menget
Partner, Paris and Africa Group
Gitta Satryani
Managing Partner, Singapore Office, Singapore
Lode Van Den Hende
Consultant, Brussels and London
Hannah Ambrose
Partner, London, Ukraine Group and Africa Group
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