The wide reach of the prohibition against circumventing EU sanctions
Against the background of Russia’s invasion of Ukraine, the EU has imposed a number of sanctions, which include a prohibition for companies within the EU to take certain measures in relation to Russia, as well as designated Russian people and entities on the sanction lists. Furthermore, a prohibition to circumvent the sanctions has been introduced in order to ensure that the sanctions are effective also in practice. When it comes to this circumvention prohibition, it is important to be aware of its wide interpretation, as established by the Court of Justice of the European Union and the European Commission.