The EU Council Decision of 26 July 2010 was only immediately effective against those to who it was addressed, i.e. the Governments of the Member States, and not against individuals or corporates. A further Regulation was required in order for the sanctions to take effect against corporates and individuals. This Regulation has been published today, 27 October 2010. It has immediate effect and does not require national implementing legislation.
This briefing note is an immediate reaction to that Regulation and its purpose is to highlight some of the key issues which emerge for our clients. It is not intended to be an exhaustive analysis of the Regulation, and further Client Alerts will inevitably follow.
The new Regulation replaces Regulation (EC) No 423/2007 and incorporates the previous restrictions on dealing with certain designated persons.
The regulation applies:
(a) within the territory of the Union, including its airspace;
(b) on board any aircraft or any vessel under the jurisdiction of a Member State;
(c) to any person inside or outside the territory of the Union who is a national of a Member State;
(d) to any legal person, entity or body which is incorporated or constituted under the law of a Member State;
Please see full Alert below for more information.
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