EU sanctions generally apply:
- within the territory of the EU;
- on board any aircraft or vessel under the jurisdiction of an EU Member State;
- to any person inside or outside the territory of the EU who is a national of an EU Member State;
- to any legal person, entity or body, inside or outside the territory of the EU, which is incorporated or constituted under the law of an EU Member State; and
- to any legal person, entity or body in respect of any business done in whole or in part within the EU.
Particular attention should be paid to the last alternative, i.e., “any business done in whole or in part within the EU”, which may–in certain limited constellations, create a long-arm jurisdiction of what would otherwise be considered as a nonextraterritorial regime.
Any party or transaction with a nexus to the EU as detailed above is subject to the EU sanctions regime. For more information, please refer to the Factsheet for EU restrictive measures.