On 3 June, the EU Sanctions blog referred to an Opinion of 27 May saying that the EU Commission had responded to queries from national competent authorities.  It said that liquidating an investment fund was permitted provided that the proceeds of the liquidation are immediately frozen, the use of the designated person’s assets is prevented, and the continuity of the asset freeze is maintained.   It also said assets could be transferred from an EU bank account to an account in the UK, so long as the asset freeze was maintained.

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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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