On 11 May, the European Commission published guidance notes, which answers questions such as what sanctions are in place, who do they apply to and what does the freezing of assets entail. The Note provides guidance on compliance obligations, and exemptions (or derogations), including those pertaining to humanitarian assistance. It also makes clear that EU operators should exercise caution when engaging with an entity owned/controlled by a listed person, and the guidance sets out how to determine the ownership/control of an entity
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