FRANCE Law and Practice Contributed by: William Julié, Amélie Beauchemin and Camille Gosson, WJ Avocats
WJ Avocats 55, rue de Prony 75017 Paris France
Tel: (+33) 1 88 33 51 80 Fax: (+33) 1 88 33 51 81 Email: info@wjavocats.com Web: www.wjavocats.com
1. Trends and Overview 1.1 Sanctions Market
used by Russia. In the energy sector, the automatic adjustment mechanism for the oil-price cap has been suspended until July 2027, while a temporary exemp - tion allows certain pre-2022 long-term contracts for Russian liquefied natural gas (LNG) exports to third countries to continue until July 2027, subject to strict reporting obligations. The package also clarified that the ban on providing LNG terminal services applies to entities indirectly owned or controlled by Russian per - sons and establishes a framework for future transac - tion bans on refineries processing Russian crude oil. The Court of Justice of the European Union, ruling on requests for preliminary rulings and appeals brought against judgments of the General Court of the CJEU, delivered several key and awaited judgments, estab - lishing standards for the framework of sanctions against Russia and Belarus. 1.2 Key Trends The top trends in France concerning sanctions in the last 12 months have all resulted from the expansion and development of tools regarding EU sanctions, including: • new listings and listing criteria; • expansion of energy-related sanctions; • expansion of restrictions on financial flux; and • new definitions and rules arising from the published decisions of the General Court and the CJEU. The Council of the EU also decided to impose sanc - tions on individuals identified as responsible for the systematic unlawful deportation, forced transfer,
Over the past 12 months, the most significant devel - opment has been the ongoing implementation of Directive (EU) 2024/1226, which requires member states to criminalise the violation and circumvention of EU restrictive measures and to harmonise criminal penalties across the Union. France has taken its first formal step in that direction with the introduction of Bill No 2544 before the National Assembly on 3 March 2026 (see 3.1 Significant Court Decisions or Legal Developments ). Sanctions of the Council of the EU have continued to expand over the last 12 months due to new sanctions packages (the 19th, 20th and 21st sanctions pack - ages) imposed by the EU in the context of the war in Ukraine. Energy-related sanctions have been expanded, par - ticularly targeting directly liquefied natural gas (LNG) and crude oil, as well as, indirectly, by the intermediary of sanctions against tankers. Restrictions on financial flux have also increased, especially on crypto-assets and bank transfers. On 23 July 2026, the Council adopted the 21st pack - age of restrictive measures against Russia, significant - ly expanding trade, financial and energy restrictions. It extended transaction prohibitions to 33 additional Russian banks and financial institutions and creates a new legal basis for a comprehensive ban on trans - actions with foreign crypto-asset service providers
137 CHAMBERS.COM
Powered by FlippingBook