On 24 March, the EU updated its paper concerning the EU Best Practices for the effective implementation of restrictive measures. The amendments introduce various non-exhaustive and non-binding recommendations by the Foreign Relations Counsellors Working Party for the effective implementation of restrictive measures by EU member states.

The key amendments to the paper include (1) a recommendation for a “transparent and effective de-listing procedure” to mirror delistings from UN sanctions lists, (2) affirmation that any sanctions measures annulled by the EU Court remain in force for the two months and ten days time limit to bring an appeal and pending such an appeal, (3) a statement that all persons or entities complying with sanctions obligations under various EU Regulations shall not be held liable for any damage caused to a designated person, (4) a restatement of the tests for “ownership” and “control” of a legal person as well as the criteria for “making indirectly available funds” to designated persons as originally published in the Guidelines on Implementation of Restrictive Measures in 2013, and (5) a list of considerations that EU authorities must take into account when granting exemptions to financial restrictive measures.

These updates amend the previous version of the paper, published on 24 April 2008.