Regulation

The notion of circumvention under EU sanctions

STEPTOE: OUTSIDE COUNSEL

The European Union (“EU”) has begun preparations to impose its 11th sanctions package against Russia, with the European Commission having tabled a proposal early May that is currently being discussed by EU Member States. A key focus of the eleventh package is to tackle the circumvention of EU sanctions, in order to plug leaks of existing sanctions.

In particular, the Commission’s proposal would target third countries as well as foreign entities that enable the cir...

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