The EU regulations that implement UN and EU sanctions applicable in France commonly contain the following grounds for obtaining licenses:

  • Basic needs—expenses necessary to support the existence of the designated person or their family (not to a standard enjoyed before being designated);
  • Legal fees and disbursements—must be reasonable and involve genuine legal advice or litigation;
  • Fees or charges for holding or maintaining frozen accounts or · economic resources;

  • Payment of court judgments or arbitral decisions against the designated person or entity—must have been given before the date of designation and cannot be for the benefit of another designated person;

  • Satisfaction of contractual obligations—obligation must have been incurred prior to the date of designation and cannot make funds available to the designated person; and

  • Extraordinary expenses—cannot be recurring or easily anticipated, and cannot be used to avoid limitations to other grounds for obtaining a license.

The French Treasury is usually responsible for granting licenses, either through so-called "general licenses" (i.e., licenses granted to a specific operator for transactions of a specific type, which remains effective until revoked) or "authorizations of a general nature" (i.e., permanent authorizations that are publicly issued).

The French Treasury website provides online forms for submitting information and reporting issues relating to (i) transactions, (ii) financial transfers, or (iii) cases of common names in sanctions lists.
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