A paper from UK Finance (a trade association representing 300 of the leading firms providing finance, banking and payments-related services in or from the UK) on 11th July seeks to provide an overview for discussion with EU Member States and the European Commission on practical aspects related to the implementation of the updated EU Blocking Regulation.  The paper deals with challenges of complying with divergent and conflicting cross-border sanctions obligations as they relate to the updated Blocking Regulation; the key areas of concern for natural and legal persons of complying with the Blocking Regulation; and priority aspects that should be included within forthcoming EU guidance which will accompany the introduction of the updated Blocking Regulation.   The paper considers a number of potential situations in an annex and poses a number of questions (and proposed answers) about how the Blocking Regulation will work.  It concludes that the existing Blocking Regulation has rarely been enforced and has not been considered to offer “any real protection” against US secondary sanctions.

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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