The EU and US Sanctions Regimes

The following EU Law practice note provides comprehensive and up to date legal information covering:

  • The EU and US Sanctions Regimes
  • European Union sanctions
  • United States sanctions
  • Comparing EU and US sanctions

The EU and US Sanctions Regimes

This Practice Note considers:

  1. EU sanctions

  2. sanctions in the US, and

  3. the similarities and differences between the EU and US sanctions regimes

Practice Note: Development of sanctions regime in the UK post Brexit—timeline explains and monitors the Sanctions and Anti-money Laundering Act 2018 which received Royal Assent on 23 May 2018. Originally proposed in the Queen’s Speech in June 2017, the Act introduces a new framework for the implementation and enforcement of international sanctions in the UK with the purpose of enabling the UK's continued compliance with international law following the Brexit transition period.

For the impact of the end of the transition period on sanctions provisions in loan agreements, see Practice Note: The effect of sanctions on loan agreements, Brexit—documentary implications for facility agreements [Archived], and Brexit checklist—finance documents [Archived].

European Union sanctions

The EU applies sanctions and restrictive measures to promote the objectives of the Common Foreign and Security Policy. The sanctions are designed to lead to a change in the policies or activities carried out by the target countries governments, companies, groups, organisations or individuals (commonly referred to as 'Persons') and their use by the EU has increased over the last ten years or so, with over 30 sanctions regimes now in place.

The EU implements sanctions, usually through EU Regulations which have direct effect in all Member States,

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