On 20th June, Eversheds Sutherland provided an update on the Blocking Regulation designed to protect EU companies from the extra-territorial effects of US sanctions on Iran. Amongst other things it makes it illegal for EU companies to comply with certain prohibitions in US sanctions legislation.  It is for the EU Member States to decide what penalties are to be imposed for breaches of the relevant provisions and, for the most part, Member States have declined to engage in any enforcement activities.  Updates are intended to deal with the re-imposition of Iran sanctions by the US following the US withdrawal from the JCPOA.  The briefing provides details of changes made and concludes by saying that the European Parliament and the Council now have a period of 2 months to object to the Proposal before it is adopted as EU law (although they may choose to signal earlier that they will not object, thus allowing the measure to come into force earlier).  The Commission hopes that the updated Blocking Regulation will come into force before 7th August, when the first set of US secondary sanctions on Iran are due to be re-imposed.


Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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