On 21 January 2019, the EU adopted the first sanctions measures1 under its new sanctions framework targeting parties involved in the use and proliferation of chemical weapons introduced in October 2018.2
The EU has imposed an asset freeze and EU-wide travel restrictions3 against five Syrian individuals and an asset freeze against the Syrian Scientific Studies and Research Centre (SSRC) for which they all work, on the basis of their involvement in the use, development, transfer and production of chemical weapons by the Syrian regime. The EU has also imposed an asset freeze and travel restrictions against four Russian military intelligence officers on the basis of their involvement in the Novichok poisoning of Sergei and Yulia Skripal and Nick Bailey in Salisbury (UK) in March 2018.
As a result of the asset freeze, all funds and economic resources belonging to, or controlled by, the listed persons and that fall under EU jurisdiction (e.g., held by EU banks) will be frozen. Furthermore, no funds or economic resources may be made available – directly or indirectly – to or for the benefit of the listed persons by parties falling under EU jurisdiction.
The asset freeze sanctions apply to the EU territory (including its airspace), to nationals of EU Member States (including those located outside the EU), and on board vessels and aircraft under Member State jurisdiction. Sanctions also apply to companies incorporated or registered under the law of an EU Member State and to other non-EU companies in respect of business done in whole or in part in the EU. This means that non-EU companies may be affected by the measures once specific parties are listed, depending on the particular circumstances in which business activities are performed in the EU.
These sanctions entered into force on 21 January 2019.
1 See Council Decision (CFSP) 2019/86 of 21 January 2019 amending Decision (CFSP) 2018/1544 concerning restrictive measures against the proliferation and use of chemical weapons, and Council Implementing Regulation (EU) 2019/84 of 21 January 2019 implementing Regulation (EU) 2018/1542 concerning restrictive measures against the proliferation and use of chemical weapons.
2 Further information on the EU's sanctions framework against the use and proliferation of chemical weapons can be found in our previous Client Alert, available here.
3 See Article 2 of Council Decision 2018/1544 of 15 October 2018 concerning restrictive measures against the proliferation and use of chemical weapons.
See also: International Sanctions
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