The EU has recently removed four persons from its asset freeze list featuring persons deemed responsible for misappropriation of Ukrainian state funds, and added 13 parties to the Syria related asset freeze list. In addition, the criteria for asset freeze listings in relation to Libya have changed (and one person was delisted). These EU asset freeze developments are described further below. 

Ukraine state fund misappropriation list The EU has published the results from a review of the asset freeze list targeting persons deemed responsible for misappropriation of Ukrainian state funds (which is separate from the asset freeze list under Regulation 269/2014 in relation to the territorial integrity, sovereignty and independence of Ukraine).1 As a result, the existing EU asset freeze list imposed under Regulation 208/2014 was reduced from 22 persons to 18 persons as of 7 March 2015. 2

According to the EU Council, the four persons (including former presidential advisers Andriy Portnov and Ihor Kalinin) in question were removed from the EU asset freeze list to account for progress in judicial proceedings on Ukrainian state fund embezzlement.3 While the underlying Council Decision featuring the remaining 18 persons was extended until 6 March 2016, four of those persons (including Viktor Yanukovych, son of the former Ukrainian President) are currently only scheduled to remain on the asset freeze list until 6 June 2015. 

Syria list

Based on a recent decision by the EU Council,4 the EU has reinforced its asset freeze against parties deemed to sponsor the Syrian regime by assisting in the production of chemical weapons, along with the supply of oil, steel and banknotes. Regulation 2015/3755 adds seven persons and six entities to the Syria related asset freeze.6

The newly-added designated parties effective 7 March 2015 are:


  1. Bayan Bitar (a.k.a. Dr Bayan Al-Bitar) (Managing Director of the Organisation for Technological Industries (OTI), and the Syrian Company for Information Technology (SCIT)
  2. Brigadier General Ghassan Abbas (Manager of the branch of the Syrian Scientific Studies and Research Centre (SSRC/CERS))
  3. Wael Abdulkarim (a.k.a. Wael Al Karim) (Managing Director of oil supply intermediary Pangates International Corp Ltd)
  4. Ahmad Barqawi (a.k.a. Ahmed Barqawi) (General Manager of Pangates International Corp Ltd)
  5. George Haswani (a.k.a. Heswani; Hasawani; Al Hasawani) (Co-owner of HESCO Engineering and Construction Company)
  6. Emad Hamsho (a.k.a. Imad Hmisho; Hamchu; Hamcho; Hamisho; Hmeisho; Hemasho) (Senior manager at Hamsho Trading and vice-president of the Syrian Council of Iron and Steel)
  7. Samir Hamsho (a.k.a. Samer; Sameer; Hmisho; Hamchu; Hamcho; Hamisho; Hmeisho; Hemasho) (Owner and chairman of Al Buroj and Syria Steel/Hmisho Steel; associated with Hamsho International, Syria Steel SA and Al Buroj Trading)


  1. Organisation for Technological Industries (a.k.a. Technical Industries Corporation (TIC)) (Subsidiary of the Syrian Ministry of Defence)
  2. Syrian Company for Information Technology (SCIT) (Subsidiary of the Organisation for Technological Industries (OTI))
  3. Hamsho  Trading  (a.k.a.  Hamsho  Group;  Hmisho  Trading  Group; Hmisho Economic Group) (Subsidiary of Hamsho International)
  4. Syria Steel SA (a.k.a. Syria Steel Co; Syria Steel Rolling Mill; Hmisho Steel) (Subsidiary of Hamsho Trading)
  5. Al Buroj Trading (a.k.a. Borouj Trading Company) (Subsidiary of Hamsho Trading)
  6. DK Group (a.k.a. DK Group SARL DK Middle East & Africa Regional Office) (Supplies new banknotes to the Central Bank of Syria)

Libya list

Finally, the EU has amended its asset freeze provisions in relation to Libya.

Through Regulation 2015/374, which entered into force on 8 March 2015,7 the EU has broadened the legal basis for Libya related asset freezes (originally featured in Regulation 204/2011).

More specifically, the EU has expanded the scope of criteria for imposing an asset freeze (and, in the case of persons, a visa ban) on certain parties in relation to Libya. Now, the EU may more broadly designate parties (and their associates) when they are deemed to be engaged in or provide support for acts that threaten the peace, stability or security in Libya, or obstruct or undermine the successful completion of Libya’s political transition.

In other words, this amended legal basis enables the EU to impose sanctions on more parties deemed responsible for human rights abuses, attacks and illicit natural resource exploitation in Libya.