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 –




If you would like to say thanks by making a small contribution, in case I need to upgrade or replace my computers and other paraphernalia, I have a page 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

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

%d bloggers like this: