EU sanctions typically apply:

  1. within the territory of the EU, including its airspace;
  2. on board any aircraft or any vessel under the jurisdiction of a EU Member State;
  3. to any person inside or outside the territory of the EU who is a national of a EU Member State;
  4. to any legal person, entity or body, inside or outside the territory of the EU, which is incorporated or constituted under the law of a EU Member State; and
  5. to any legal person, entity or body in respect of any business done in whole or in part within the EU.

Moreover, EU sanctions typically provide for “catch-all” provisions according to which it shall be prohibited to participate, knowingly and intentionally, in activities the object or effect of which is to circumvent the measures set forth in the relevant Regulation.

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