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For companies subject to U.S. economic sanctions regimes, compliance is complicated by Regulation (EC) No 2271/96 (EU Blocking Regulation), which was updated in 2018 in light of the U.S. position on Iran. An illustration of this can be found in the recent judgement by the Court of Justice of the EU (CJEU) (Grand Chamber) in Bank Melli Iran v Telekom Deutschland.

Click here to read the full GT Alert.

Tags: CJEU, Court of Justice, economic sanctions, GT Insight, international trade, Iran, Technology Media & Telecommunications
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Photo of Erik de Bie Erik de Bie

Erik de Bie is an attorney-at-law focused on international trade, customs and VAT matters. Erik counsels clients in European trade, export control, sanctions, customs, VAT and excise duty related matters, including litigation. He concentrates his practice on developing and implementing European savings programs…

Erik de Bie is an attorney-at-law focused on international trade, customs and VAT matters. Erik counsels clients in European trade, export control, sanctions, customs, VAT and excise duty related matters, including litigation. He concentrates his practice on developing and implementing European savings programs, setting up and restructuring European distribution and supply chains, improving and structuring customs, excise duty and VAT related compliance, and limiting risks and liabilities. Given the developments in European legislation and the needs of his clients, Erik is frequently involved in cross-border matters, including obtaining certification as Authorized Economic Operator (AEO), implementing customs bonded warehouse regimes and counseling on VAT issues.

Erik represented (and represents) many companies before Dutch Tax and Customs Courts, the Dutch Supreme Court, the European Commission, and the European Court of Justice.

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Photo of Kara M. Bombach Kara M. Bombach

Kara Bombach assists companies and organizations to lawfully export goods, technology and services around the globe. She places emphasis on helping clients achieve practical, workable solutions to complex regulatory situations arising under anti-corruption and anti-bribery measures (U.S. Foreign Corrupt Practices Act (FCPA) and

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Kara Bombach assists companies and organizations to lawfully export goods, technology and services around the globe. She places emphasis on helping clients achieve practical, workable solutions to complex regulatory situations arising under anti-corruption and anti-bribery measures (U.S. Foreign Corrupt Practices Act (FCPA) and OECD Convention), export control laws (EAR and ITAR), anti-boycott laws, and special sanctions (embargoes) maintained by the U.S. government (OFAC and other agencies) against various countries (including Iran, Cuba and Russia), entities and individuals. In cases of foreign investment in the United States, Kara advises on the Exon-Florio provisions relating to U.S. national security concerns. She represents companies before the Committee on Foreign Investment in the United States (CFIUS), and also assists clients in mitigating foreign ownership, control or influence (FOCI) as may be required by CFIUS or U.S. national industrial security regulations.

Kara regularly represents clients in matters before U.S. government agencies, including the U.S. Departments of Commerce, State, Treasury and Defense. Kara has significant experience representing individuals and entities before OFAC in delisting matters and challenges to OFAC sanctions designations.

She advises national and multi-national companies (including Fortune® 5) on best practices in the development and delivery of compliance policies and procedures, training, and risk assessments, as well as executing cross-border export, sanctions and anti-corruption due diligence in mergers and acquisitions, targeted internal risk assessments, and compliance investigations.

Kara also counsels international not-for-profit and relief/aid organizations on best practices in economic sanctions, trade, and anti-corruption compliance issues that arise in their global operations, frequently in challenging and austere environments. She has provided legal services to organizations such as Save the Children (US), ONE Campaign, Mercy Corps, the International Committee of the Red Cross, Not on Our Watch/The Sentry, and The Enough Project.

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Photo of Hans Urlus Hans Urlus

Hans Urlus focuses his practice on antitrust and competition issues affecting clients in various industry sectors, and handles competition matters on both the domestic and cross-border level, with a concentration on vertical competition law issues regarding market entry strategies. Hans has vast experience…

Hans Urlus focuses his practice on antitrust and competition issues affecting clients in various industry sectors, and handles competition matters on both the domestic and cross-border level, with a concentration on vertical competition law issues regarding market entry strategies. Hans has vast experience advising clients on EU and national competition law, and EU regulatory issues, including handling complex multi-jurisdictional mergers and acquisitions.

Hans also coordinates inbound and outbound FDI with respect to China and represents international clients in all legal and regulatory aspects of international trade, commercial agency, and franchise and distribution law issues. He is also involved in litigation and arbitration in relation to these matters. In addition, Hans also counsels various multinational clients on Dutch corporate law and governance obligations regarding holding activities.

Hans also deals with other regulatory aspects of EU law and the Dutch implementation thereof, such as the Anti-Money Laundering (AML) and Anti-Terrorist Financing Act (in Dutch: Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft)).

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Photo of Robert Hardy Robert Hardy

Dr. Robert Hardy, LL.M. (Harvard) is a Local Partner in the firm’s Amsterdam office. He advises clients on matters spanning a wide spectrum of economic sectors, including consumer products, energy, financial services, manufacturing, life sciences, TMT, and transportation.

Robert focuses his practice on:…

Dr. Robert Hardy, LL.M. (Harvard) is a Local Partner in the firm’s Amsterdam office. He advises clients on matters spanning a wide spectrum of economic sectors, including consumer products, energy, financial services, manufacturing, life sciences, TMT, and transportation.

Robert focuses his practice on:

  • Antitrust Litigation & Competition Regulation
  • International Trade
  • Regulatory & Compliance.
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