On 23 March 2012, the Council of the European Union (EU) adopted Implementing Regulation 265/2012, which for the first time added legal entities to the asset freeze list in Annex IB of Regulation 765/2006 concerning restrictive measures in respect of Belarus.2 Regulation 265/2012 entered into force on 24 March 2012 (the date of publication).
The EU Belarus sanctions regime has been in force since May 2006 and applies within the EU territory, to nationals of EU Member States (regardless of whether they are located inside or outside the EU territory) and on board vessels and aircraft under Member State jurisdiction. It also applies to companies incorporated or registered under the law of an EU Member State and to non-EU companies in respect of any business done in whole or in part within the EU. This means that even non-EU companies can be covered by EU sanctions, depending on the particular circumstances under which they perform business activities in the EU and how these are connected to any activities restricted by the Regulation.
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