The European Council on Foreign Relations has published this briefing on “secondary sanctions”.  It defines primary and secondary sanctions in the context of US sanctions as –

  • Primary sanctions prohibit companies and individuals in the sanctioning country from engaging with their counterparts in the sanctioned country. Such sanctions apply to US persons, as well as US-origin goods and transactions that take place on US territory or in which the US can assert its jurisdiction; and
  • Secondary sanctions are generally directed towards foreign persons. These measures threaten to cut off foreign individuals or companies from the US financial system if they engage in certain conduct with a sanctioned entity, even if none of that activity touches the US directly.

The paper assesses Europe’s main vulnerabilities to secondary sanctions and proposes policies that will restore its freedom of action – or, at least, minimise these measures’ impact.  It says that Europe’s exposure to US secondary sanctions is a major foreign policy challenge for which there is no easy solution, particularly in the light of re-imposed US sanctions following its withdrawal from the JCPOA on Iran.

See also this briefing from the Atlantic Council in February 2018 –

This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at

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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