Sanctions 2026

FRANCE Trends and Developments Contributed by: William Julié, Amélie Beauchemin and Camille Gosson, WJ Avocats

beginning of a new chapter in the judicial elaboration of EU sanctions law, not its conclusion. Conclusion Beyond their implications for trusts, the 21 May 2026 judgments are reflective of a broader trend in EU sanc - tions law, towards an increasingly expansive interpre - tation of the concepts linking assets to designated persons. By favouring economic reality over formal legal arrangements, the Court continues to extend the reach of restrictive measures. In doing so, it seeks to limit opportunities for circumvention and to ensure that sanctions remain effective.

Yet the pursuit of effectiveness cannot come at the expense of legal certainty. As the concepts of owner - ship, control and economic benefit become broader and more fact-dependent, it becomes increasingly difficult for trustees, financial institutions, corporate service providers and other economic operators to assess whether particular assets may be regarded as falling within the scope of asset-freeze obligations. The challenge for future case law will therefore be to strike an appropriate balance between the effective - ness of restrictive measures and the predictability that economic operators require to organise their affairs and comply with their obligations. The lasting signifi - cance of these judgments may ultimately lie less in the answers they provide than in the questions they leave open as to where that balance should be drawn.

157 CHAMBERS.COM

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