Sanctions 2026

FRANCE Law and Practice Contributed by: William Julié, Amélie Beauchemin and Camille Gosson, WJ Avocats

forced assimilation and unlawful adoption of Ukrain - ian minors in May 2026. 1.3 Key Industries Sectors in France particularly affected by EU sanc - tions pursuant to Council Decision 2014/512/CFSP and Council Regulation (EU) No 833/2014 include oil, finance, banking and dual-use goods. Sectors in which natural persons who are under sanc - tions are involved, or used to be involved, are also affected, as third-party actors refuse to work with all natural and legal persons even remotely linked to them, even if these links are only historic. In particu - lar, this concerns sectors such as fertilisers, oil, coal and IT. 1.4 Overview 1.4.1 Types of Sanctions France implements both individual sanctions, target - ing natural and legal persons, and sectoral sanctions, decided at the UN, EU and national levels. Individual sanctions include travel bans and the freez - ing of assets, and sectoral sanctions include embar - goes and other restrictions on the export and import of certain goods. 1.4.2 Scope of Sanctions The scope of France’s sanctions as an EU member state is broad (though narrower than US sanctions, as the EU does not apply secondary sanctions), as EU sanctions must be complied with by: • anyone present in the territory of the EU, including its airspace; • anyone on board any aircraft or any vessel under the jurisdiction of an EU member state; • all nationals of an EU member state, even when outside of the territory of the EU; • any legal person, entity or body, inside or outside the EU, incorporated or constituted under the law of a member state; and • any legal person, entity or body in respect of any business done in whole or in part within the EU. First, autonomous sanctions imposed by the French authorities (which are not a mere application of EU or

UN restrictive measures) do not have extraterritorial effects. Second, regarding the scope of application of EU sanctions, they must be complied with by: • any person inside or outside the territory of the EU who is a national of a member state, and by any legal entity (Article 13 (c) of Regulation 833/2014 and Article 17 (c) of Regulation 269/2014); • any legal person, entity or body, inside or outside the territory of the EU, which is incorporated or constituted under the law of a member state; and • any legal person, entity or body in respect of any business done in whole or in part with the EU. Although the EU has historically maintained that its sanctions have no extraterritorial effect, this has been called into question since the 11th Russia package (June 2023). The package created the possibility, as an exceptional and last-resort measure, of prohibiting the sale, supply, transfer or export from the Union of certain goods and technologies (in particular sensi - tive dual-use items and items liable to contribute to Russia’s military and technological reinforcement or to the development of its defence and security sector) the export of which to Russia is already restricted, to third countries found to present a continuing and par - ticularly high risk of being used to circumvent those restrictions. Article 8a of Regulation 833/2014, in force since June 2024, sets out a “best efforts” obligation: “Natural and legal persons, entities and bodies shall under - take their best efforts to ensure that any legal person, entity or body established outside the Union that they own or control does not participate in activities that undermine the restrictive measures provided for in this Regulation”. 1.4.3 Domestic and/or Supranational Measures In France, sanctions are imposed at three different levels. • National: France has autonomous sanctions regimes in four areas: counterterrorism (Article L. 562-2 of the French Monetary and Financial Code); foreign interference (Article L. 562-2-1 CMF); drug

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