EU Law and Practice Contributed by: Edward Borovikov, Laurens Engelen, Xiaoyi Tang and Semen Medvedkov, Dentons
Dentons Dentons Europe LLP Rue de la Regence 58 box 2 1000 Brussels Belgium Tel: +32 2 552 29 00 Fax: +32 2 552 29 10 Email: brussels@dentons.com Web: www.dentons.com
1. Trends and Overview 1.1 Sanctions Market
ments addressing the provision of humanitarian aid in sanctions environments affected by EU counter- terrorism measures and regimes concerning Iran, Nicaragua and Venezuela, including questions aris - ing in the context of the COVID-19 pandemic. It clari - fies how humanitarian exceptions and derogations should operate in practice and reiterates that impar - tial humanitarian organisations and beneficiaries of aid are not the target of EU sanctions. 1.2 Key Trends Over the past 12 months, the EU has adopted multiple additional sanctions packages against Russia. These measures include further export restrictions and new listings of Russian individuals and companies, as well as designations of actors in third countries such as China, the United Arab Emirates and certain financial and commercial operators in Central Asia considered to be facilitating or supporting the circumvention of existing EU sanctions. In addition, the EU has used its existing Iran sanctions regime to list two individuals and one entity linked to actions undermining freedom of navigation through the Strait of Hormuz. These listings, which target those involved in running a toll and control system for commercial vessels, illustrate the EU’s readiness to apply sanctions to protect critical maritime routes and global energy and trade flows. Moreover, the EU has renewed most of its existing sanctions regimes, while repeatedly updating the Rus - sia and Belarus frameworks; it has also expanded sev - eral horizontal regimes, including counter‑terrorism
The EU maintains tailored sanctions regimes targeting over 40 different countries, territories and non-govern - mental organisations. The past year’s developments in the EU were driven primarily by the ongoing war in Ukraine. This includes stricter restrictions on financial trade, services, energy, technology and other sectors deemed critical to the Russian economy, as well as the further development of sanctions targeting Bela - rus. Further, geopolitical situations and human rights concerns have prompted the EU to also implement additional sanctions regimes or expand the existing ones throughout the world. In parallel, the EU has significantly stepped up its focus on implementation, enforcement and circum - vention risks, including through dedicated anti-cir - cumvention measures in recent sanctions packages against Russia. In this context, the EU has also listed multiple individuals and entities in third countries such as China that it considers to be involved in facilitating, supporting or enabling the circumvention of EU sanc - tions against Russia. These efforts are complemented by guidance for operators and humanitarian actors to support compliant conduct while mitigating unin - tended impacts of sanctions on legitimate activities. The European Commission’s (the “Commission”) horizontal guidance on the provision of humanitarian aid in compliance with EU sanctions remains a key reference point for organisations, banks and other intermediaries. This guidance builds on earlier docu -
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