EU Updates Ownership, Control Language in Sanctions Guidance

The EU this month updated its set of best practices to help member states better implement sanctions. The 42-page guidance, issued by the Council of the European Union, outlines how new designations should be applied, how governments should approach delisting, the roles of companies and other “economic operators,” areas and procedures for coordinating sanctions with other agencies and countries, and more.

The updated guidance includes new language on how sanctions should be applied to entities owned or controlled by a designated person, Ruta Bajarunaite, a sanctions official with the Lithuanian government, said on LinkedIn. It specifically lists the criteria that should be used "when assessing whether a legal person or entity is controlled by another person or entity," how agencies should approach the use of trusts, shell companies and limited liability companies, and more.