The Council of Europe’s Economic Crime and Cooperation Division, in cooperation with the European Commission (Directorate General for Structural Reform Support – DG REFORM) hosted the Project Closing Conference “Implementation of EU sanctions’ regime: status of practice and the way forward” which took place on 13 June 2023 in Brussels, Belgium.

The event was convened with the aim of presenting the project results and achievements. Representatives from twenty-two EU Member States had thus the opportunity to reflect on conclusions that could be drawn from the studies conducted and the multilateral discussions held throughout the ten months of project implementation.

One of the main project achievements underlined during the event concerned the high-level involvement of the majority of EU Member States. Although the project was initiated at the request of three beneficiaries – the Czech Republic, Latvia and Malta – it has very quickly expanded to the remaining twenty-four jurisdictions. The project has therefore benefitted from a significant number of contributions, and it also provided an important platform for sharing experience between practitioners across the EU.

Moreover, the project succeeded to achieve an active involvement of the private sector. More than 750 representatives of virtual assets service providers (VASPs), banking sector, payment institutions, trust and company service providers (TCSPs), legal professionals, and other, have benefitted from awareness-raising activities on effective implementation of EU sanctions’ regime.

As a result, the project has completed four studies whose findings shall assist National Competent Authorities (NCAs) in further improving their work in order to ensure a better implementation of EU Sanctions’ regime. Good practices have for instance been identified as regards the identification of persons holding effective control of a company and the possibility of taking over the management of a company owned by sanctioned individuals. NCAs have also been provided with a number of case studies and practical examples as regards the freezing and seizing of assets owned by sanctioned persons and legal entities.

The project has also looked into the risks of sanctions’ evasion through the use of VASPs, by identifying existing deficiencies in their market entry and supervision mechanisms, as well as related sanctions trends and risks, aiming to identify risk mitigation strategies. To further support the NCAs in this regard, the project has also provided beneficiaries with analysis of blockchain analytics tools available on the market.

The project closing event was also an opportunity to reflect on the way forward as regards the effective implementation of EU sanctions’ regime. Updates regarding the latest regulatory initiatives were provided by DG FISMA representatives and DG TRADE. The latter has also provided an overview as regards the practical implementation of EU restrictive measures in trade and exports sector. Moreover, a summary of existing challenges for a harmonised implementation of EU sanctions was presented by Council of Europe experts, together with proposed solutions. One of the presentations also touched upon the prevention of sanctions’ evasion through the use of VASPs, from the perspective of upcoming developments following the adoption of Markets in Crypto-assets (MiCA) Regulation. Finally, the discussion also focussed on the lessons to be drawn from the practical implementation of UN sanctions. 

The Conference was also an opportunity to kick-off on the follow-up TSI initiative “Effective implementation of the sanctions regime and enhanced cross-border cooperation in EU Member States” which will provide technical support and assistance for nine beneficiary EU Member States – Czech Republic, Cyprus, Denmark, Hungary, Lithuania, Malta, Romania, Slovenia and Spain – and will allow to ensure the continuity of the technical assistance in respect of effective implementation of EU sanctions. 

The activity was organised within the framework of the Technical Support Instrument (TSI) initiative on “Effective and uniform implementation of the sanctions’ regime in EU Member States”, funded by the European Commission Directorate General for Structural Reform Support and the Council of Europe, and implemented by the Council of Europe.