US Sanctions and the EU Blocking Regulation: Issues of Legal Uncertainty

The London-based  Financial Markets Law Committee has published a report on extension of Regulation (EC) No 2271/96 protecting against the effects of the extra-territorial application of legislation adopted by a Third Country to cover Iran post-JCPOA.  The role of the Committee is to identify issues of legal uncertainty or misunderstanding, present and future, in the framework of the wholesale financial markets which might give rise to material risks and to consider how such issues should be addressed.  This paper examines the issues of legal uncertainty which arise under English law as a result of the amendment to the Blocking Regulation to cover certain re-imposed US sanctions on Iran, and seeks to illustrate particular areas of risk that the Committee has identified as a result of these uncertainties.

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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