“It is a common mistake for businesses to believe that if you are based in the US or compliant with US OFAC provisions, then EU sanctions do not apply to you. This is not the case. US parents with subsidiaries and wider business affiliates in the EU need to ensure compliance with domestic, host and wider international law.
US sanctions prohibit transactions by US citizens regardless of where they are located. Similarly, EU sanctions will apply to entities incorporated in any EU member state, all individuals and entities within the EU and again, all EU citizens regardless of where they are located. Businesses with an international presence or whose employees travel for business therefore need to carefully consider their position.”
Read the full update, The Expansion of EU Sanctions, Dechert LLP»