In July, the European Commission published an Opinion on whether an EU bank should freeze funds belonging to a non-designated person that were transferred from a designated intermediary bank.  It appeared that the non-designated person wanted access to their legally owned funds in order to buy a house.  It was also asked if the funds could be released under the exception for “extraordinary expenses” under the relevant Iranian sanctions regulation.  The Commission said that the funds had to be frozen, but that the legal owner could take advantage of the exception if they met the conditions applied to use of the exception, such as the expense being unexpected, unforeseen, and unavoidable in the light of the purpose and, while the acquisition of a house does not appear to qualify in itself as extraordinary expenditure it is for the national authorising authority to make the final decision.

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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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