United States: Expanded EU Economic Sanctions On Iran, Syria, Libya, And Belarus

This week, the European Union (EU) extended the asset freeze and admission ban to additional individuals for Syria1, Libya2, Belarus3, and Iran4, as well as to new entities in Iran ( see attached list). The expansion of the restrictions is the result of the deterioration of conditions in these countries, mainly further harassment of political opposition and, with respect to Iran, circumvention attempts.

The expansion of the Iranian asset freeze is mainly the result of a number of investigations with respect to attempts by Islamic Republic of Iran Shipping Line (IRISL) to circumvent sanctions by using front companies, including in the EU. Also, a number of other Iranian companies, involved in procurement of equipment and components for the Iranian nuclear industry, were listed. This is the first time so many European companies have been subjected to sanctions.

The extension of Syrian sanctions to top Syrian officials is the result of the EU concluding that previous sanctions were ineffective in stemming the regime's crack-down on opposition. If the situation in Syria does not improve, further sanctions will be considered.

The extension of Belarusian sanctions is the result of recent sentences in political trials stemming from last year's presidential elections. A new round of economic sanctions on Belarus, which may include asset freeze on state-owned entities as well as other measures, is also being discussed.

More detailed information regarding the measures implemented, by country, is below.

Iran - The EU extended the existing asset freeze to five individuals, officials from the Atomic Energy Organization of Iran (AEOI) and a substantial number of entities, mainly related to IRISL. Targeted Iran entities are involved in a wide range of industries such as petroleum, banking, shipping, and transportation in addition to nuclear-related. The extension of sanctions to 73 companies related to IRISL confirms the seriousness with which the EU treats restriction of IRISL's circumventing activities. The newly designated entities include:

  • A number of Iranian entities involved in procurement of materials and equipment in Iran's nuclear program;
  • Two subsidiaries of the AEOI;
  • A Belarusian bank co-owned by a number of designated Iranian banks;
  • Two Malaysian companies;
  • Two UAE companies involved in procurement of components for Iranian nuclear program;
  • Thirty-seven German entities, either owned or controlled by the IRISIL, other designated persons, or one German-Iranian bank involved in circumventing EU sanctions on financial transactions;
  • Twelve Isle of Man entities, either IRISL subsidiaries, or controlling ship-owning companies in Hong Kong;
  • Nineteen Hong Kong companies, owning ships operated by SAPID (which took over IRISL's bulk business); and
  • Six Maltese companies and a Cypriot company, ultimately controlled by IRISIL.

Syria - The EU has expanded the existing asset freeze and travel ban to additional 10 individuals, mainly high-level Syrian officials (including the Syrian President Bashar Al-Assad and Vice President Faruq Al Shar), as well as two businessmen: Mohamed Hamcho, and Ihab Makhlouf (Vice President of SyriaTel). In addition, the EU suspended all ongoing bilateral programs with Syria (e.g., canceled the signing of the Association Agreement with Syria, suspended funding from the European Neighbourhood and Partnership Instrument and under the Euro-Med partnership) and has asked the European Investment Bank not to approve new financing operations in Syria. If the situation in Syria does not improve, the EU is ready to take further measures.

Libya - The EU has expanded its asset freeze to Afriqiyah Airways (owned by the already sanctioned Libyan-African Investment Portfolio), and its asset freeze and ban on admission to Taher Juwadi, a member of the Quadhafi regime. In addition, official talks on how to use the frozen assets for the benefit of the Libyan population and the opposition have begun within the Council.

Belarus - Following recent sentencing of political opponents in trials before Belarusian courts, the EU has extended its asset freeze and visa ban to 13 additional judges, prosecutors, and other public officials in Belarus. The question of extending the sanctions to state-owned entities (as called for by the European Parliament's resolution of 12 May 2001 and pushed by a number of EU Member States) continues to be on the agenda.

For detailed information about the individuals and entities that are targeted, please see the attached list. In the meantime, we will continue to follow this and report on any new developments.


1 Council Implementing Regulation (EU) No 504/2011 of 23 May 2011 implementing Regulation (EU) No 442/2011 concerning restrictive measures in view of the situation in Syria, OJ L 136 Volume 54, 24 May 2011, p45-47; Council Implementing Decision 2011/302/CFSP of 23 May 2011 implementing Decision 2011/273/CFSP concerning restrictive measures against Syria, OJ L 136 Volume 54, 24 May 2011, p91-94

2 Council Implementing Regulation (EU) No 502/2011 of 23 May 2011 implementing Regulation (EU) No 204/2011 concerning restrictive measures in view of the situation in Libya, OJ L 136 Volume 54, 24 May 2011, p24-25; Council Implementing Decision 2011/300/CFSP of 23 May 2011 implementing Decision 2011/137/CFSP concerning restrictive measures in view of the situation in Libya; OJ L 136 Volume 54, 24 May 2011, p85-86

3 Council Implementing Regulation (EU) No 505/2011 of 23 May 2011 implementing Regulation (EC) No 765/2006 concerning restrictive measures against President Lukashenko and certain officials of Belarus, OJ L 136 Volume 54, 24 May 2011, p48-51; Council Implementing Decision 2011/301/CFSP of 23 May 2011 implementing Decision 2010/639/CFSP concerning restrictive measures against certain officials of Belarus; OJ L 136 Volume 54, 24 May 2011, p87-90

4 Council Implementing Regulation (EU) No 503/2011 of 23 May 2011 implementing Regulation (EU) No 961/2010 on restrictive measures against Iran, OJ L 136 Volume 54, 24 May 2011, p26-44; Council Decision 2011/299/CFSP of 23 May 2011 amending Decision 2010/413/CFSP concerning restrictive measures against Iran; OJ L 136 Volume 54, 24 May 2011, p65-84

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

In association with
Related Topics
Related Articles
Related Video
Up-coming Events Search
Font Size:
Mondaq on Twitter
Mondaq Free Registration
Gain access to Mondaq global archive of over 375,000 articles covering 200 countries with a personalised News Alert and automatic login on this device.
Mondaq News Alert (some suggested topics and region)
Select Topics
Registration (please scroll down to set your data preferences)

Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice):

  • To allow you to personalize the Mondaq websites you are visiting to show content ("Content") relevant to your interests.
  • To enable features such as password reminder, news alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our content providers ("Contributors") who contribute Content for free for your use.

Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below.

Mondaq has a "free to view" business model. Our services are paid for by Contributors in exchange for Mondaq providing them with access to information about who accesses their content. Once personal data is transferred to our Contributors they become a data controller of this personal data. They use it to measure the response that their articles are receiving, as a form of market research. They may also use it to provide Mondaq users with information about their products and services.

Details of each Contributor to which your personal data will be transferred is clearly stated within the Content that you access. For full details of how this Contributor will use your personal data, you should review the Contributor’s own Privacy Notice.

Please indicate your preference below:

Yes, I am happy to support Mondaq in maintaining its free to view business model by agreeing to allow Mondaq to share my personal data with Contributors whose Content I access
No, I do not want Mondaq to share my personal data with Contributors

Also please let us know whether you are happy to receive communications promoting products and services offered by Mondaq:

Yes, I am happy to received promotional communications from Mondaq
No, please do not send me promotional communications from Mondaq
Terms & Conditions

Mondaq.com (the Website) is owned and managed by Mondaq Ltd (Mondaq). Mondaq grants you a non-exclusive, revocable licence to access the Website and associated services, such as the Mondaq News Alerts (Services), subject to and in consideration of your compliance with the following terms and conditions of use (Terms). Your use of the Website and/or Services constitutes your agreement to the Terms. Mondaq may terminate your use of the Website and Services if you are in breach of these Terms or if Mondaq decides to terminate the licence granted hereunder for any reason whatsoever.

Use of www.mondaq.com

To Use Mondaq.com you must be: eighteen (18) years old or over; legally capable of entering into binding contracts; and not in any way prohibited by the applicable law to enter into these Terms in the jurisdiction which you are currently located.

You may use the Website as an unregistered user, however, you are required to register as a user if you wish to read the full text of the Content or to receive the Services.

You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these Terms or with the prior written consent of Mondaq. You may not use electronic or other means to extract details or information from the Content. Nor shall you extract information about users or Contributors in order to offer them any services or products.

In your use of the Website and/or Services you shall: comply with all applicable laws, regulations, directives and legislations which apply to your Use of the Website and/or Services in whatever country you are physically located including without limitation any and all consumer law, export control laws and regulations; provide to us true, correct and accurate information and promptly inform us in the event that any information that you have provided to us changes or becomes inaccurate; notify Mondaq immediately of any circumstances where you have reason to believe that any Intellectual Property Rights or any other rights of any third party may have been infringed; co-operate with reasonable security or other checks or requests for information made by Mondaq from time to time; and at all times be fully liable for the breach of any of these Terms by a third party using your login details to access the Website and/or Services

however, you shall not: do anything likely to impair, interfere with or damage or cause harm or distress to any persons, or the network; do anything that will infringe any Intellectual Property Rights or other rights of Mondaq or any third party; or use the Website, Services and/or Content otherwise than in accordance with these Terms; use any trade marks or service marks of Mondaq or the Contributors, or do anything which may be seen to take unfair advantage of the reputation and goodwill of Mondaq or the Contributors, or the Website, Services and/or Content.

Mondaq reserves the right, in its sole discretion, to take any action that it deems necessary and appropriate in the event it considers that there is a breach or threatened breach of the Terms.

Mondaq’s Rights and Obligations

Unless otherwise expressly set out to the contrary, nothing in these Terms shall serve to transfer from Mondaq to you, any Intellectual Property Rights owned by and/or licensed to Mondaq and all rights, title and interest in and to such Intellectual Property Rights will remain exclusively with Mondaq and/or its licensors.

Mondaq shall use its reasonable endeavours to make the Website and Services available to you at all times, but we cannot guarantee an uninterrupted and fault free service.

Mondaq reserves the right to make changes to the services and/or the Website or part thereof, from time to time, and we may add, remove, modify and/or vary any elements of features and functionalities of the Website or the services.

Mondaq also reserves the right from time to time to monitor your Use of the Website and/or services.


The Content is general information only. It is not intended to constitute legal advice or seek to be the complete and comprehensive statement of the law, nor is it intended to address your specific requirements or provide advice on which reliance should be placed. Mondaq and/or its Contributors and other suppliers make no representations about the suitability of the information contained in the Content for any purpose. All Content provided "as is" without warranty of any kind. Mondaq and/or its Contributors and other suppliers hereby exclude and disclaim all representations, warranties or guarantees with regard to the Content, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. To the maximum extent permitted by law, Mondaq expressly excludes all representations, warranties, obligations, and liabilities arising out of or in connection with all Content. In no event shall Mondaq and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use of the Content or performance of Mondaq’s Services.


Mondaq may alter or amend these Terms by amending them on the Website. By continuing to Use the Services and/or the Website after such amendment, you will be deemed to have accepted any amendment to these Terms.

These Terms shall be governed by and construed in accordance with the laws of England and Wales and you irrevocably submit to the exclusive jurisdiction of the courts of England and Wales to settle any dispute which may arise out of or in connection with these Terms. If you live outside the United Kingdom, English law shall apply only to the extent that English law shall not deprive you of any legal protection accorded in accordance with the law of the place where you are habitually resident ("Local Law"). In the event English law deprives you of any legal protection which is accorded to you under Local Law, then these terms shall be governed by Local Law and any dispute or claim arising out of or in connection with these Terms shall be subject to the non-exclusive jurisdiction of the courts where you are habitually resident.

You may print and keep a copy of these Terms, which form the entire agreement between you and Mondaq and supersede any other communications or advertising in respect of the Service and/or the Website.

No delay in exercising or non-exercise by you and/or Mondaq of any of its rights under or in connection with these Terms shall operate as a waiver or release of each of your or Mondaq’s right. Rather, any such waiver or release must be specifically granted in writing signed by the party granting it.

If any part of these Terms is held unenforceable, that part shall be enforced to the maximum extent permissible so as to give effect to the intent of the parties, and the Terms shall continue in full force and effect.

Mondaq shall not incur any liability to you on account of any loss or damage resulting from any delay or failure to perform all or any part of these Terms if such delay or failure is caused, in whole or in part, by events, occurrences, or causes beyond the control of Mondaq. Such events, occurrences or causes will include, without limitation, acts of God, strikes, lockouts, server and network failure, riots, acts of war, earthquakes, fire and explosions.

By clicking Register you state you have read and agree to our Terms and Conditions