1. Introduction
In response to the escalating violence in Syria, the Council of the European Union (EU) agreed on 25 June 2012 to reinforce its sanctions against Syria. The Council decided to further develop the applicable restrictions related to the provision of financial assistance in the context of the arms embargo1 and to subject additional parties to an asset freeze.2
 
Regulation 545/2012 (which amends Regulation 36/2012)3 and Implementing Regulation 2012/544/CFSP both entered into force on 26 June 2012.  
 
As before, these new restrictions apply to the EU territory (including its airspace), to nationals of EU Member States (including those located outside the EU), and on board any vessel or aircraft under Member State jurisdiction. The Regulation also applies to companies incorporated or doing business in whole or in part in a Member State. This means that non-EU companies could be covered, depending on the particular circumstances under which they perform business activities in the EU and how they are connected (e.g. through their insurance providers) to any activities restricted by the Regulation.
  1. Restrictions related to the provision of financial assistance for goods subjected to the arms embargo
Council Regulation 545/2012 clarifies the scope of the existing ban on the provision of financing or financial assistance related to the goods and technology listed in the Common Military List or items that can be used for internal repression as listed in Annex I or IA to Regulation 36/2012, by explicitly adding the provision of insurance or reinsurance to the nonexhaustive list of transactions that are covered by this ban.
 
This clarification follows a recent incident involving a UK-insured Russian cargo ship carrying helicopters for Syria, in which the British security services forced the UK insurance provider to cancel the insurance for the ship, thus forcing the vessel to discontinue its journey and return to the port of departure.
 
As a consequence of this clarification, ships carrying goods and technology listed in the Common Military List, or in Annexes I and IA to Council Regulation 36/2012, will not be able to use the services of European insurance providers, regardless of the origin of the goods or technology or the nationality of the ship.  
 
The Council also expanded the ban on the provision of technical assistance for internal repression products to also cover goods and technology which might be used for the manufacture and maintenance of products listed in Annexes I or IA to Council Regulation 36/2012.
  1. Addition of 1 natural person and 6 legal entities to the asset freeze list
Implementing Regulation 2012/544/CFSP imposes an asset freeze for six further entities supporting the regime (the Ministry of Defence, the Ministry of Interior, the Syrian National Security Bureau, the Syria International Islamic Bank (SIIB), the General Organisation of Radio and TV, and the Syrian Company for Oil Transport) and targets one additional natural person (a Political and Media Advisor to the President) with a travel ban and an asset freeze.
 
As of 26 June 2012, all funds and economic resources owned or controlled by these parties that fall under EU jurisdiction will be frozen. Additionally, no funds or economic resources can be made available – directly or indirectly - by any person falling under EU jurisdiction to those listed persons or entities.  
 
This new round of sanctions brings the total number of parties affected by the EU asset freeze to 129 persons and 49 entities.