EU-based Industrial Company – Challenges related to the EU sanctions

We assisted an EU-based industrial company on the applicability of the EU sanctions upon their product and service supply to Russia. We drafted a legal opinion on the matter to support the business decision of the company’s future operations in Russia.

As in other sanctions cases, the challenge was the absence of detailed reference material and published case law. Another challenge identified was the different approaches of the various Member States’ national authorities to the sanctions, for although EU sanctions regulations and decisions are universally applicable, there is not always consensus among Member States upon how to interpret those regulations and decisions. This lack of consensus decreases the legal certainty related to cross-border business activities.