On 10 November, the EU Sanctions blog reported that the EU Commission has amended its Russia sanctions FAQ on its asset freeze and the prohibition on making funds available, and on oil imports.  One new FAQ deals with situations where oil which originates in a third country is mixed during transport with that which is controlled and which originates in Russia.  Another deals with company voting rights being viewed as an intangible asset.

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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