EU Issues Guidance on Sanctions 'Firewalls'

The European Commission released a guidance note May 3 pertaining to the implementation of "firewalls" that allow EU entities controlled by sanctioned individuals and entities to trade in agricultural products, including wheat and fertilizers. The firewall "removes the control by the designated person so that the EU entity’s business operations in the trade in agricultural and food products, including wheat and fertilisers can continue, while keeping the funds and economic resources owned by the designated person frozen." The guidance discusses the requirements of a firewall, including "entities for which a firewall may be established," as well as the implementation of a firewall. The guidance breaks down firewalls by legislation and operators and the exchange of information concerning cross-border situations.