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An EU Member State is obliged to freeze the assets of an undertaking where a sanctioned person or entity exercises control over that undertaking and may adopt national implementing measures to that end. The control in question must be substantiated by objective and sufficiently robust evidence. The form of government of a state, even if […]

If a company is wound up by means of a turbo liquidation (also known as fast-track liquidation) without the director fulfilling their duty to notify creditors, this may result in liability on the part of that director. This is evident from a judgment of The Hague District Court dated 8 July 2026 (ECLI:NL:RBDHA:2026:21059). What were […]

In Jenec (Case C-81/24), the Court of Justice of the European Union (CJEU) held that a bank must first carry out an individual assessment of the money-laundering and terrorist-financing risk associated with the proposed relationship. An OFAC listing may justify enhanced scrutiny. It is not an automatic ground for refusal. The judgment matters to banks, […]

It is safe to say that, after more than four years of targeting Russia’s economy, the package introduces no groundbreaking new measures. The 21st package signals the EU’s willingness to maintain pressure, but it also seems that further reaching economical restrictions increasingly require concessions from individual Member States that those states have shown themselves unwilling […]

Anyone who is aware of a problem and conceals it cannot, in the event of a breach of warranties, hide behind the buyer’s duty to investigate. This is clear from a recent judgment by the Amsterdam District Court (ECLI:NL:RBAMS:2026:4722). What were the facts of this case? In 2021 and 2022, an investor provided loans to […]

EU-based companies exporting dual-use items will usually start their export-control assessment with EU law. In particular, they will consider whether Regulation (EU) 2021/821 requires an export authorization and whether the destination, end-user or intended end-use gives rise to additional restrictions. That EU-law assessment may not always be sufficient. Where a product, software, technology or production […]