Highlights

In a recent ruling, the Court of Justice of the European Union (CJEU) upheld the legality of confiscating the proceeds from brokering services relating to military equipment manufactured in Russia and sold from Ukraine to India, without entering the European Union. This decision highlights the increasingly broad reach of EU sanctions and the EU’s dedication to enforcing sanctions and preventing circumvention.

This is also a clear sign to all EU operators providing brokering services to implement robust due diligence mechanisms to ensure that they are not captured by prohibitions under EU sanctions should underlying goods be in any way linked to Russia. In addition, the CJEU gave a clear signal of support to the European Commission and the relevant authorities of EU Member States prosecuting violations of EU sanctions, assuring them of a pro-enforcement line of CJEU case law.

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