EU Guidance

European Council & Commission

Since 2012, the European Council and Commission have published guidance, in various forms, in relation to the imposition and enforcement of EU economic sanctions. The following are guidelines currently in force:

  • EU Restrictive Measures Factsheet, 29 April 2014. This document provides a general overview of the types of restrictive measures available, e.g. arms embargo, asset freeze, travel bans, etc.
  • LMA Guidance: EU sanctions relating to Ukraine and Russia: Prohibition on new loans and credit introduced by Council Regulation (EU) 296/2014, 21 October 2014.
  • EU Best Practices on Sanctions, 4 May 2018. This document addresses the identification and designation of persons/entities subject to restrictive measures. It also provides a detailed explanation of the financial restrictive measures.
  • Commission Guidance Note on the implementation of certain provisions of Regulation (EU) No 833/2014, 25 August 2017. This guidance addresses the implementation of restrictive measures targeting sectoral cooperation and exchanges with the Russian Federation. In particular, it provides guidance on the application of certain provisions in Regulation (EU) No 833/2014, including guidance on areas such as financial assistance, financial services measures, loans and capital markets.
  • Commission FAQs on EU restrictive measures in Syria, 1 September 2017.
  • Information Note to EU business on operating and/or investing in Crimea/Sevastopol, 25 January 2018.
  • Guidelines on implementation and evaluation of restrictive measures in the framework of the EU Common Foreign and Security Policy, 4 May 2018. This document addresses general issues and presents standard wording and common definitions that may be used in the legal instruments implementing restrictive measures. It provides guidance on the interpretation of ‘ownership and control’ of an entity and making indirectly available funds or economic resources to designated persons and entities. It also addresses the issue of information sharing between Member States.
  • Guidance Note on the import and export ban on luxury goods under Council Regulation 2017/1509 (restrictive measures towards DPRK), 31 January 2019.
  • Due Diligence Helpdesk on EU sanctions for EU SMEs dealing with Iran, launched 11 October 2020
  • Sanctions Tool Iran, launched 11 October 2020
  • EU Commission Guidance Note on the provision of humanitarian aid to countries and areas subject to EU sanctions (Syria, Iran, Venezuela, Nicaragua, terrorism sanctions), updated on 13 August 2021.
  • EU Commission Guidance Note on the implementation of certain provisions of Council Regulation (EU) 401/2013 (Myanmar), 11 May 2021
  • Guidance Note on due diligence for EU businesses to address the risk of forced labour in their operations and supply chains, 12 July 2021
  • Q&A: Due Diligence on restrictive measures for EU businesses dealing with Iran
  • Consolidated List of EU sanctions targets (EU Login required)
  • EU Sanctions Map
  • List of member state competent authorities

Commission Opinions

  • Commission Opinion on Article 5(4) of Council Regulation (EU) 2016/44 – handling frozen funds located in and outside Libya, 7 June 2019.
  • Commission Opinion on the export ban established by Council Regulation (EU) 692/2014, 4 July 2019.
  • Commission Opinion on freezing funds of a non-designated person transferred from a designated bank, and the “extraordinary expenses” under Art 28 of Council Regulation (EU) 267/2012, 4 July 2019.
  • Commission Opinion on provision of higher education in the framework of a prohibition to provide technology or technical assistance to a third country, 5 August 2019. 
  • Commission Opinion on the application of derogations from the freezing of funds and from the prohibition to make funds and economic resources available to designated persons and entities, 29 August 2019.
  • Commission Opinion on Article 5(1) of Council Regulation (EU) No 833/2014 (Russia sectoral sanctions), 17 October 2019.
  • Commission Opinion on the compatibility of national asset freezes imposed by Member States with Union law, 8 November 2019.
  • Commission Opinion on the application of Article 2 of Council Regulation (EU) 269/2014 (restrictive measures in view of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine), 19 June 2020.
  • Commission Opinion on changes to the features of frozen funds (Libya, Syria), 27 May 2021.
  • Commission Opinion on the release of frozen funds under Council Regulation (EU) No 224/2014 (Central African Republic), 2 June 2021.
  • Commission Opinion on the interpretation of Article 2(2) of Council Regulation (EU) 269/2014 (restrictive measures in view of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine), 8 June 2021.

European Parliament

European Data Protection Supervisor (EDPS)

  • Opinion on various legislative proposals imposing certain specific restrictive measures in respect of Somalia, Zimbabwe, the Democratic Republic of Korea and Guinea, 23 March 2010.
  • Opinion on the proposal for a Council Regulation amending Regulation (EC) No 881/2002 imposing certain specific restrictive measures directed against certain persons and entities associated with Usama bin Laden, the Al-Qaida network and the Taliban, 17 November 2011.
  • Opinion on a notification for Prior Checking received from the Data Protection Officer of the European Commission regarding the Processing of personal data in connection with regulations requiring asset freezing as CFSP related restrictive measures, 22 February 2012.
  • Joint Opinion on the notifications for Prior Checking received from the Data Protection Officer of the Council of the European Union regarding the processing of personal data for restrictive measures with regard to the freezing of assets, 7 May 2014.

EU Blocking Regulation

  • Briefing: European Parliamentary Research Service: Updating the Blocking Regulation, June 2018.
  • Guidance Note: Q&A on the adoption of update of the Blocking Regulation, 7 August 2018.
  • See here for template to help EU operators prepare and submit their application for authorisation to comply with foreign restrictive measures.
  • Commission Implementing Regulation (EU) 2018/1101 laying down the criteria for the application of Article 5, second paragraph of Council Regulation (EC) No 2271/96 of 22 November 1996 protecting against the effects of the extra-territorial application of legislation adopted by a third country, and actions based thereon or resulting therefrom.
  • Report: US Sanctions and the EU Blocking Regulation: Issues of Legal Uncertainty – Financial Markets Law Committee, June 2019.
  • Strategy for “The European economic and financial system: fostering openness, strength and resilience”, 19 January 2021
  • EU Commission Initiative (including impact assessment): Unlawful extra-territorial sanctions – a stronger EU response (amendment of the Blocking Statute)
    • Feedback to inception impact assessment
  • Report from the EU Commission to the European Parliament and the Council relating to Article 7(a) of Council Regulation (EC) No 2271/96 (‘Blocking Statute’), 3 September 2021

Covid-19

  • EU Commission Guidance on EU restrictions on exports of personal protective equipment outside of the EU, 20 March 2020.
  • EU Commission Guidance (FAQs) on EU restrictions on exports of personal protective equipment outside of the EU, 29 April 2020.