A major challenge for economic operators with regard to European Union financial sanctions law is the sometimes inconsistent and contradictory interpretation of the rules amongst the Member States. In February 2013, the Council of the European Union adopted new interpretative guidelines with regard to the interpretation of the prohibition to make available funds or economic resources through persons or entities owned or controlled by listed persons or entities. While coherent interpretation has - partially - been established, the new guidelines continue to raise issues of legal certainty and reverse the burden of proof under financial sanctions law.
Global Trade and Customs Journal