Blocking Regulation: the first step towards solving the conflict of laws between EU and US sanctions
Lourdes Catrain
Attorney-at-Law, Partner, Hogan Lovells International LLP, Belgium
Eleni Theodoropoulou
Attorney-at-Law, Associate, Hogan Lovells International LLP, Belgium
Published 25 Jan 2022

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The Court of Justice of the EU has interpreted for the first time the Blocking Regulation. The ruling confirms that it is possible to terminate contracts with a US designated person without providing reasons. However, in civil proceedings it is for the EU party to prove that, when it sought to terminate a contract, it did not seek to comply with US sanctions in the absence of an authorisation by the European Commission.