Monday June 24, 2024 the EU published amended sanctions regarding the situation with Russia. Most important changes we noted;
- a provision for voluntary self disclosure was made, similar to the US. This means that EU Member State national competent authorities have the possibility to take that self-disclosure into account when applying penalties.
- It is made clear that within the EU, companies need to duly take into account publicly or readily available information when carrying out due diligence (customer and transaction related). When such information is not considered during due diligence, a Union operator cannot successfully invoke protection from that "they did not know" and "had no reasonable cause to suspect". So make sure your due diligence on your counterparties and transactions is sufficient! We can help you to achieve this.
- Persons and Companies in the EU who are able to and effectively assert a decisive influence over the conduct of a company established outside the Union, they may incur responsibility for actions of that company that undermine the EU restrictive measures and should use their influence to prevent those actions from occurring.