On 18 January 2012, the Council of the European Union (EU) adopted the EU's new sanctions regime against Syria in Council Regulation 36/2012 ("the New Syria Sanctions Regulation" or "New Regulation") which provides for new sanctions on the participation in the construction of electric power plants, new export and import restrictions for software and telecom equipment and technology, and broadens existing sanctions related to the oil and gas industry, as well as the existing restrictions related to the transfer of funds and the provision of financial services. The original Syria Sanctions Regulation (i.e. Regulation 442/2011) is repealed as from 19 January 2012 and replaced by the New Regulation, which is binding and has direct application in all Member States, and implements and clarifies Council Decision 2011/782/CFSP of 1 December 2011.
As before, the new Syria Sanctions Regulation applies 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 to any activities restricted by the Regulation.
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