Update of the Council’s Sanctions Best Practices: when should persons not listed on EU sanctions lists nonetheless be treated as sanctioned?

Editorial note: Sanctions are one of the examples of growing number of border restrictions and prohibitions. This is impacting a number of companies involved in global trade. The nature of sanctions is becoming more diverse and the list of sanctioned persons is growing. As a result, importers, exporters and other actors have no choice but to be more careful in choosing who they work with. Especially in light of the recent updates by the Council of the European Union on the understanding of who is a sanctioned person.