The Council of the European Union has published a revised version of its guidance on financial sanctions, “EU Best Practices for the Effective Implementation of Restrictive Measures”.
The revised guidance provides some clarification of the many issues which arise in practice for both Member States and for persons and entities subject to financial sanctions or otherwise affected by their application. Significant uncertainties in the interpretation of EU sanctions do, however, remain.
a Herbert Smith briefing identifying the main amendments to the guidance, which appear to envisage an increasing role for the private sector in the implementation of financial sanctions is available here.
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