On 24 June, Eversheds Sutherland published an article saying that on 19 June the EU published new guidance following requests from several Member State national authorities. The guidance relates to EU sanctions imposed, chiefly on Russian persons and entities, in respect of the annexation of Crimea etc. The Commission states that it is for national authorities to take into account all the elements at their disposal and the specific circumstances of the case to determine whether the designated person has control and, if it is established that the designated person does have control over the entity then the assets of that entity must also be frozen. The guidance complements the previously published 2018 best practices for implementation of restrictive measures (i.e. sanctions).
The guidance is at –
The 2018 sanctions best practice document is at –
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