The updated version of the EU Blocking Regulation enters into force

On 7 August 2018, the European Union (EU) published: (1) Commission Delegated Regulation (EU) 2018/1100 (amending regulation), which expands the scope of Regulation (EC) No 2271/96 (EU blocking regulation) to the extraterritorial effects of certain U.S.-Iran sanctions (covered U.S.-Iran sanctions); (2) Commission Implementing Regulation (EU) 2018/1101 (authorization regulation), which sets out the procedure and conditions for EU economic operators to be authorized to comply with the U.S. covered Iran sanctions; and (3) a guidance note that aims to clarify certain aspects of the EU blocking regulation (as amended by the amending regulation) (guidance note).

These steps were taken to protect EU economic operators from the reimposition of the U.S.-Iran sanctions following the United States' withdrawal from the Joint Comprehensive Plan of Action (JCPOA) in May 2018 (see previous alert on the topic).

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