Energy Sanctions: the European Union's Approach

摘要

As is clear from this short summary of the EU's key energy sanctions, the Iran Sanctions represent the high-water mark of restrictive measures applicable to the energy industry-the prohibitions are so extensive as to make attempting to do energy-related business in Iran or with Iranian persons almost impossible. The Russia Sanctions demonstrate an alternative approach. Through both geographical and subject matter targeting, the energy sector can, in the main, continue most business in Russia as long as it remains vigilant, and implements appropriate compliance processes and risk assessments, protects itself in its contracts with tailored sanctions clauses and has a system whereby high-risk transactions or other scenarios are elevated for legal attention as soon as they arise. So, while certain political and commercial imperatives are met by the exceptionally targeted approach of the Russia Sanctions, and while there are significant commercial benefits to that approach, such precise measures can be the hardest with which to comply in practice.