Sanctions Profile: United States

At a glance

Initial Imposition of EU sanctions & Subsequent Amendments

These sanctions are relatively unique in that they are not imposed against the USA, per se, but rather to protect EU individuals and businesses from the extra-territorial effect of US laws regarding carrying out business in Iran, Libya and Cuba.

The measures began in 1996 and empowered Member States to take measures to protect the interests of the relevant individuals and businesses.

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UN Sanctions

There are no UN sanctions in force against the USA. EU sanctions are imposed pursuant to the EU’s autonomous Common Foreign and Security Policy powers.

Provisions in Force

Joint Action 1996/668/CFSP (OJ L 309, 22 November 2006) contains: protection against effects [extra-jurisdictional] of certain US sanctions.

Council Regulation (EC) No 2271/1996 (OJ L 309, 22 November 1996) contains: protection against effects [extra-jurisdictional] of certain US sanctions.

Amended by Council Regulation (EC) No 807/2003 (OJ L 122, 14 April 2003) amendment to align committee procedures.

Amended by Regulation (EU) No 182/2011 of the European Parliament and the Council (OJ L 55, 16 February 2011) amendment to process of consulting Committee that assists the Commission.

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UK updates regs criminalising breach of EU Blocking Statute

On 1 February 2019, the Extraterritorial US Legislation (Sanctions against Cuba, Iran and Libya) (Protection of Trading Interests) (Amendment) Order 2018 (SI 2018/1357) came into force. This UK Order ensures that UK criminal offences extend to conduct by UK nationals and entities within the scope of the amended Blocking Statute (on which see previous blog).

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Initial ICJ hearing in Iran’s sanctions case against USA

We reported last month that Iran has brought proceedings against the USA in the International Court of Justice (ICJ) in the Hague over the 8 May US decision to withdraw from the JCPOA and reimpose sanctions on Iran. See Iran’s application and ICJ press release. Iran’s claim is that the US reimposition of sanctions violates […]

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Updated EU Blocking Statute: legal provisions, authorisation criteria & guidance

The updated EU Blocking Statute came into force today (7 August 2018), see Commission Delegated Regulation (EU) 2018/1100 amending Council Regulation (EC) No 2271/96. The Blocking Statute allows EU operators to recover damages arising from the extra-territorial sanctions within its scope from the persons causing them and nullifies the effect in the EU of any […]

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Updated EU Blocking Statute in force tomorrow

The European Commission announced today that the updated EU Blocking Statute (see previous blog) will enter into force on 7 August 2018 (tomorrow), in response to the re-imposition of US sanctions on Iran. They have also issued a document explaining its effect (EU Commission Q&As) which states that: The Blocking Statute aims at countering the effects […]

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Turkey responds to US measures

We reported last week that the US had added Turkey’s Minister of Justice Abdulhamit Gul and Minister of Interior Suleyman Soylu to its Global Magnitsky sanctions list (Executive Order 13818) over the “leading roles” they played in the arrest and detention of US Pastor Andrew Brunson. In response, Turkey’s President Recep Tayyip Erdogan announced on […]

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Current Sanctions