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EU Implements a New Sanctions Regime for Human Rights Violations

On 7 December 2020, the Council announced the establishment of a new legal regime for the EU to impose human rights sanctions on individuals or legal entities.

The new regime is described in two documents, the Council decision 2020/1999 concerning restrictive measures against serious human rights violations and abuses, and the Regulation of the same name. Regulation 2020/1998 came into force on 8 December 2020 and is directly applicable across the EU. In addition, a list of persons that are subject to sanctions ("Designated Persons") is attached to the regulation as an annex. New persons may be added to the sanctions list by proposal of any EU Member State or the Union’s High Representative for Foreign Affairs and Security Policy.

The list may include:

  • persons (physical or legal) responsible for serious or widespread human rights violations such as genocide, crimes against humanity, slavery, sexual and gender-based violence, and other as listed in Art. 2 of the Regulations;
  • persons who provide financial, technical, or material support for, or are otherwise involved in, the above violations; and
  • others associated with the persons included in any of the above categories.

Human rights violations, wherever committed, may lead to a number of restrictive measures applied to the Designated Persons, such as: 

  • travel restrictions; and
  • sanctions applying to the assets (freezing assets and blocking transactions) of individuals and legal entities involved in, or associated with persons responsible for, human rights violations. 

It is further required that all funds and economic resources belonging to, or owned or controlled by, any Designated Person be blocked. Furthermore, no funds or economic resources may be made available directly or indirectly to, or for the benefit of, any such person.

The new sanctions regime may therefore apply to a wide variety of persons and lead to a significant adverse economic effect not only for the Designated Persons but also for their contractual counterparties. 

For further details, please contact Partner Oleksandr Onufrienko, Private Clients practice, or Senior Associate Mykola Melnychuk.

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