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.
https://www.ecfr.eu/page/-/4_Meeting_the_challenge_of_secondary_sanctions.pdf
See also this briefing from the Atlantic Council in February 2018 –
https://www.atlanticcouncil.org/blogs/econographics/ole-moehr-3
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