Whether an unlisted company is caught by the asset freeze applicable to its shareholder was tested twice in 2026. In EM System, a case under the Belarus regime, the Court of Justice confirmed a rebuttable control presumption at exactly 50%. In Inter Rao Lietuva, it required objective and sufficiently solid evidence where control is alleged without a sufficient ownership basis. OFSI's £4.7 million Citibank penalty shows the operational cost of freezing too late. This article explains what those developments mean for counterparty screening, how the UK and US rules differ from the EU framework, and what the file should contain.
On 23 July 2026, the Council of the European Union formally adopted its 21st package of restrictive measures against Russia - the largest single round of designations since the full-scale…
What a territorial import ban is, the EU bans in force, and how goods clear one - by proving, in the right form, that they do not originate in the…
Who counts as the exporter differs across the customs code, the dual-use regulation and the anti-torture regulation - and naming the wrong one can leave an export unlicensed.
How EU sanctions restrict goods by commodity code, the national measures member states add on top, who must comply, and the penalties - the full EU picture for traders.
Who is an EU sanctioned person, who designates them, and what is prohibited - including the 50% ownership rule that catches companies on no list, and the penalties.
In this article, we focus on the constantly evolving and highly complex legal landscape of EU sanctions imposed on third countries. We explore whether artificial intelligence (AI) can enable more…
