On 23 July 2012, the Council of the European Union (EU) decided to expand its sanctions against Syria by designating another 26 persons and three entities as subject to the EU’s asset freeze. In addition, the EU Member States agreed to make inspections for suspected arms and internal repression equipment cargo obligatory, while exempting certain academic fund transfers from the asset freeze provisions.

Relevant Council Implementing Regulation 673/2012 (which amends Regulation 36/2012) and Decision 2012/420/CFSP (amending Decision 2011/782/CFSP) were both published in the EU’s Official Journal on 24 July 2012 and entered into force on the same day.

As before, these restrictions apply to the EU territory (including its airspace), to nationals of EU Member States (including those located outside the EU), and on board any vessel or aircraft under Member State jurisdiction. The Regulation also applies to companies incorporated or doing business in whole or in part in a Member State. This means that non-EU companies could be covered, depending on the particular circumstances under which they perform business activities in the EU and how they are connected (e.g. through their insurance providers) to any activities restricted by the Regulation.

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