Further to our March 4 advisory on the European Council Regulation No. 204/2011, which implements and expands upon the recent UN sanctions against Libya, a further regulation (Council Implementing Regulation No 233/2011) was published on March 11 adding additional Libyan parties to the EU sanctions list.

One person and five entities have been added to the list contained in Annex III of Regulation No 204/2001 which lists parties designated by the EU, including the Libyan Investment Authority and the Libyan Central Bank. EU persons and entities must freeze any assets belong to or controlled by the newly designated entities and are prohibited from providing funds or economic resources to those parties, either directly or indirectly.

As noted in our earlier alert, EU regulations are directly applicable in all of the 27 EU member states. Consistent with other EU sanctions regulations, the Libya sanctions will apply to any EU nationals or entities organized under the laws of an EU member state (irrespective of where they are operating), any person or entity acting within the jurisdiction of an EU member state, or on board any aircraft or vessel under the jurisdiction of a member state.

As is the case with the UN and other international sanctions regimes against Libya, the EU measures are liable to shift depending on how the situation in Libya continues to unfold, and it is possible that further Libyan parties could face sanctions designations. EU heads of state and government met on March 11 at an extraordinary meeting of the European Council to discuss developments in Libya and North Africa and to set the political direction and priorities for future EU policy and action. The European Council expressed its deep concern over the attacks against civilians; pledged to work with the United Nations, the Arab League, the African Union and international partners to respond to the crisis; and called for a summit between the Arab League, the African Union, and the European Union.