Sanctions 2025

EU Law and Practice Contributed by: Edward Borovikov, Laurens Engelen, Aurore Ancion and Semen Medvedkov, Dentons

• Technology: restrictions on technology exports to limit access to the advanced technologies needed for various industries and to impede economic development. • Defence: sanctions may target specific military equipment or technology, limiting the ability to modernise military capabilities. In addition, the EU has a strict framework that controls the export of goods that have a potential military application (so- called dual-use goods). 1.4 Overview 1.4.1 Types of Sanctions The EU has a toolbox of “restrictive measures” (sanc - tions) that it can use in several ways, including the following: • implementation of UN resolutions: when the UN Security Council imposes sanctions, the EU can translate them into its own laws and enforce them within its member states; • strengthening existing UN sanctions: the EU can go beyond UN measures by adding stricter sanc - tions of its own; and • acting autonomously: the EU can develop and implement its own sanctions regimes to address specific situations. The EU primarily adopts targeted and sectoral sanc - tions. Targeted sanctions prohibit all transactions or other dealings with specific individuals and entities. They virtually always include asset freezes and travel bans. Sectoral sanctions are generally both broader and narrower than targeted sanctions. They are broader in the sense that they provide restrictions on trans - actions with a wider category of targets. They are narrower, however, in that they tend to only prohibit certain types of dealings. Sectoral sanctions may also broadly prohibit dealing in any military or dual-use goods. 1.4.2 Scope of Sanctions EU sanctions apply: • within the jurisdiction (territory) of the EU; • to EU nationals in any location;

• to companies and organisations incorporated under the law of a member state – including branches of EU companies in third countries; and • on board aircraft or vessels under member states’ jurisdiction. Consequently, they must be complied with by: • any individual within the territory of the EU; • any individual on board any aircraft or any vessel under the jurisdiction of an EU member state; • any national of an EU member state, wherever located; • any legal entity incorporated or established under the laws of an EU member state, wherever located; and • any individual or legal entity in respect of any busi - ness done in whole or in part within the EU. These persons and entities are commonly referred to as “EU persons”. 1.4.3 Domestic and/or Supranational Measures The EU implements sanctions mandated by the United Nations Security Council as well as its own autonomous sanctions regimes, while it may also – in a hybrid manner – autonomously build on regimes that are implemented based on UN sanctions regimes. Sanctions are adopted at EU level. They are generally agreed by consensus within the Council of the EU, following proposals from the High Representative of the Union for Foreign Affairs and Security Policy. Dis - cussions take place in the relevant Council working groups. Restrictive measures are specified in Com - mon Foreign and Security Policy (CFSP) Council Deci - sions. If these decisions involve economic or finan - cial measures, they must be implemented through a Council regulation. The High Representative and the European Commission, primarily led by the Directo - rate-General for Financial Stability, Financial Services and Capital Markets Union (DG FISMA), then present a joint proposal for a regulation. This joint proposal is reviewed and discussed by the appropriate Council 2. Overview of Regulatory Field 2.1 Primary Regulators

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