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The UK passes new Order making it a criminal offence to breach the EU Blocking Statute

Posted by Sam Fowler-Holmes on Feb 8, 2019 11:21:08 AM

By Sam Fowler-Holmes and Fiona Luong

UK companies who are trading or are considering trading with Iran may now face potential criminal penalties for breaching the EU Blocking Statute, underscoring the need to carry out due diligence in order to best manage their risk profile. This includes:

  • assessing whether any authorisations are required from either the US or EU in relation to current and future business activities (e.g. by obtaining the EU Commission’s authorisation to comply with specified US extraterritorial sanctions); and
  • weighing up the risks associated with breaching US extraterritorial sanctions against those of breaching the EU Blocking Statute and updating internal policies, protocols, and business plans (where appropriate).

This may cause problems for parties who will be caught between US sanctions and UK/EU requirements.

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Topics: international trade, EU Blocking Statute, Amendment Order

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Ellis Lawson is a partner in the Trade & Export Finance Group in Sullivan's London office. He has extensive experience across a wide range of finance products and geographies, having spent significant portions of his career based both in London and in the Middle East and having advised on transactions across Europe, the Middle East and Africa. Ellis is also a speaker for Sullivan's Trade & Export Finance webinars.

 

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