⚖ Yet another instance of a broad interpretation being given to #sanctions regime concepts, making European sanctions frameworks increasingly expansive (and #sanctionscompliance increasingly complex). Thanks, Polina Lyadnova and Yulia Solomakhina, for the opportunity to work on this!
On October 23, 2023, the European Commission updated its non-binding FAQs relating to the EU’s Russia-related sanctions regime, specifically on the meaning of ‘acting on behalf or at the direction of’ an entity in the context of sanctions targeting state-owned enterprises.
