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  • Compliance & Business Integrity
  • 11-10-2017

In connection with its presidency of the Council of the European Union, Estonia launched a website at the Tallinn Digital Summit consisting of map of the world and an explanation of EU sanctions. The purpose of the EU Sanctions Map is to make information about EU sanctions more readily accessible and clear.

Until now, Europe did not have a handy overview of EU sanctions despite the fact that sanctions are frequently announced in connection with the EU’s security and foreign policy. It was a shame that all Member States had to individually answer the same questions over and over again and had to draft their own explanations, especially since all information was and is already available online, though it was not always easy to find. An Estonian news website explained that that is why Estonia developed the EU Sanctions Map as its 'digital contribution' in connection with its presidency of the Council of the European Union.

As the name already suggests, the EU Sanctions Map presents a map of the world listing the countries that are subject to EU sanctions. Simply click on a country to see what sanctions are in place and what kind of sanctions they are, e.g. restrictions on the export of military equipment or dual use items, financial restrictions or the freezing of funds. Clicking on ‘legal acts’or ‘guidelines’ also gives you access to links to underlying regulations and explanatory notes where available (such as the EU Common Military List, the European List of Dual-Use Items en guidance notices issued by the European Commission). The website furthermore offers the possibility to check persons and entities against the sanctions lists.

It is important to always bear in mind the fact that sanctions may in fact be in place against parties even though they do not appear on the sanctions lists. This can be the case, for example, where such parties are in the hands of a directly sanctioned party that does appear on a list. An act or transaction can also be subject to sanctions based on the type of goods or services, or the location of the project associated with an act or transaction. This means that it will not suffice to check only the immediate parties concerned and the underlying parties. For more information on this topic, read our earlier blog Prison sentence for prohibited indirect trading with Iran.

Unfortunately, this means that assessing sanctions will never really be easy, but the website is most certainly a step in the right direction to assessing the sanction risks associated with your business operations, clients and other related parties. As the 'most digital presidency of the Council of European Union ever’, Estonia has until 31 December 2017 to work on its digital objectives for the EU. After that date, Estonia will pass on the responsibility for the website to the European Commission. We are curious as to whether the EU will continue this great initiative.

Please feel free to contact us if you have any questions about sanctions.

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