EU adds Algerian national to ISIL & A-Q sanctions list

Terrorist.jpgThe EU has added Algerian national Rabah Tahari to its ISIL (Da’esh) and Al-Qaeda sanctions list (asset freeze imposed). See Council Decision (CFSP) 2018/1000, Council Implementing Regulation (EU) 2018/999, and UK OFSI Notice.

This is the second person to be designated under these sanctions. French national Fabien Clain was the first to be designated in February 2018 (previous blog).

EU adopts targeted sanctions framework against Maldives

EU1Today, the EU announced that it has adopted a framework to impose targeted sanctions (travel ban and asset freeze) against those responsible for “undermining the rule of law or obstructing an inclusive political solution in the Maldives”, as well as those responsible for “serious human rights violations”.

This decision is a direct follow up to the EU conclusions (26 February 2018) adopted in respect of the situation in the Maldives (previous blog).

EU implements UN de-listing of Iraq’s State Organisation of Grain

EU4Earlier this week, the UN Security Council removed the ‘General Establishment for Grain Trading’ from its Iraq sanctions list (previous blog).

Yesterday, the EU implemented this UN delisting by adopting Commission Implementing Regulation (EU) 2018/979. As a result, the body will no longer be subject to EU asset freezing measures. UK OFSI Notice here.

EU Parliament backs proposal for European Investment Bank work in Iran

European Parliament2.jpgIn light of the recent US decision to withdraw from the JCPOA and to reimpose sanctions on Iran, the EU Parliament approved last week (4 July 2018) the first reading of a Commission Delegated Decision which adds Iran to the list of countries eligible for investment activities by the European Investment Bank (EIB) (the EIB’s External Lending Mandate). The Delegated Decision, however, will not oblige the EIB to work with Iran.

This measure, along with the EU’s amended Blocking Statute (previous blog), forms the EU’s strategic approach to protecting European companies from the extraterritorial effects of US Iran sanctions.

EU extends Russian sectoral sanctions for 6 months

EU6.jpgThe EU has prolonged its sanctions targeting the financial, energy and defence sectors of the Russian economy until 31 January 2019, see Council Decision (CFSP) 2018/964 (we reported last week that EU leaders had agreed to continue the sanctions). The EU measures were originally introduced in July 2014 for 1 year (and strengthened in September 2014) in response to “Russia’s actions destabilising the situation in Ukraine”. EU press release here (includes a summary of the sanctions prolonged by this Decision).

Statement from Joint Commission of JCPOA

Iran-US.jpgToday, the Joint Commission of the JCPOA (the body responsible for overseeing the implementation of the JCPOA) held a ministerial level meeting in Vienna to discuss the continued implementation of the Iran nuclear deal in light of the recent US decision to withdraw from the agreement and to reimpose sanctions on Iran. Statement here.

The meeting was chaired by EU High Representative Federica Mogherini and was attended by representatives from China, France, Germany, Russia, UK and Iran. They all reconfirmed their commitment to the full and effective implementation of the nuclear deal, and affirmed their commitment regarding the following objectives:

·         The maintenance and promotion of wider economic and sectoral relations with Iran;

·         The preservation and maintenance of effective financial channels with Iran;

·         The continuation of Iran’s export of oil and gas condensate, petroleum products and petrochemicals;

·         The continuation of sea (including shipping and insurance), land, air and rail transportation relations;

·         The promotion of export credit cover;

·         Clear and effective support for economic operators trading with Iran, particularly SMEs;

·         The encouragement of further investments in Iran;

·         The protection of economic operators for their investment and other commercial and financial activities in or in relation to Iran;

·         The bringing together of private and public-sector experts, including through the promotion of Business Councils;

·         The practical support for trade with and investment in Iran; and

·     The protection of companies from the extraterritorial effects of US sanctions (see previous blog on the updating of the EU Blocking Statute).

Parliamentary committee concerned about lack of clarity re EU Blocking Regulation


The House of Commons European Scrutiny Committee has made a number of comments in its 33rd Report (3 July 2018) about the EU Blocking Regulation being extended to Iran sanctions (see previous blog). In particular it notes that:

1.      The practical impact of the EU Blocking Regulation is not clear, because “its enforcement in the 1990s in response to the extraterritorial effects of previous US sanctions—targeting commercial links with Iran, Libya and Cuba—was fragmented at best.”

2.      If the US administration is not responsive to “the pressure exerted by the reactivation of the Statute, it puts EU and UK companies in the position of having to choose between risking enforcement measures at home (if they choose to comply with the American sanctions) or in the US (if they abide by the Blocking Statute and ignore the US legislation).”

3.      It is good that the UK is “pressing” the European Commission for guidance, “given the potential commercial ramifications of being shut out of the American market.”

4.      The European Investment Bank has already expressed concern about being asked to provide investment support for Iran to compensate for restrictions on private investment because it requires access to US capital markets for its general operations, and “similar concerns are likely to abound in the private sector as well”.

On 18 June 2018, the UK Secretary of State for International Trade Liam Fox published an Explanatory Memorandum saying the UK supports the EU proposal and intends to “uphold the policy intent of this regulation in our statute book once we have left the EU, so that we can mitigate the impact of extra-territorial sanctions on [UK] trading interests”. The UK “will be engaging at a national level and EU level to ensure that business gets as much clarity and guidance as possible” on how to comply with the amended Regulation.

EU removes Bassam Sabbagh from Syria sanctions list

EU3In May 2018, the EU updated and extended its Syria sanctions until 1 June 2019 by adopting Council Decision (CFSP) 2018/778 and Council Implementing Regulation (EU) 2018/774 (see previous blog).

Today, the EU has corrected both of those legal acts by removing the individual named ‘Bassam Sabbagh’ from its Syria sanction list (no longer subject to an asset freeze). See Corrigendum to the Council Decision and Corrigendum to the Council Implementing Regulation.