The Council of the European Union recently published a revised version of the EU Best Practices for the effective implementation of restrictive measures. The guidance it contains provides some clarification of the many issues which arise in practice for both Member States and for persons and entities subject to sanctions or otherwise affected by their application. Significant uncertainties in the interpretation of EU sanctions do, however, remain.
Our briefing identifies the main amendments, which appear to envisage an increasing role for the private sector in the implementation of restrictive measures.
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