On 19 January, the European Commission published a Communication setting out its new strategy with wide-ranging ideas which suggest far more active involvement by the Commission in EU sanctions than previously, to counter “the extra-territorial application” of unilateral sanctions by third countries (such as the US), and to promote the uniform implementation and enforcement of EU sanctions and monitor their effectiveness.
A new Sanctions Information Exchange Repository will be a database for reporting and exchange of information between the Commission and Member States on the implementation and enforcement of sanctions and there will be a single point of contact for cross-border enforcement and implementation in the EU. There will be a system for anonymous reporting of sanctions evasion, including whistleblowing. From 2021, the Commission will conduct a review of practices that circumvent and undermine sanctions, including the use of cryptocurrencies, and the results of this will inform possible legislative proposals or implementation guidelines from 2022.
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