On 19th December, the UK published the Extraterritorial US Legislation (Sanctions against Cuba, Iran and Libya) (Protection of Trading Interests) (Amendment) Order 2018. EU Regulation 2271/96/EC (the “Blocking Regulation”) prohibits EU companies and individuals from complying with sanctions imposed by the US on Cuba, Iran and Libya, insofar as such sanctions purport to have effect on these companies and individuals outside of the US. The Blocking Regulation forbids EU natural and legal persons from complying with those sanctions, unless exceptionally authorised to do so by the EU Commission. The Blocking Regulation also allows EU operators to recover damages arising from the relevant extra-territorial sanctions from the persons causing said damage and nullifies the effect in the EU of any foreign court rulings based on them. These new regulations update the original UK Order of 1996 so that it refers to the updated Blocking Regulation.
EU information on the Blocking Regulation is available at –