Answer given by Ms McGuinness on behalf of the European Commission

13.10.2023

Natural and legal persons required to comply with EU restrictive measures (sanctions) have an obligation to take the necessary measures to ensure such compliance and to act in accordance with any contractual obligation vis-à-vis other parties. The same sanctions apply to all companies across the EU.

Disputes arising from such obligations must be solved pursuant to the relevant contractual obligations and in accordance with applicable national laws. They may be subject to judicial review.

The Council Regulations regarding the EU sanctions against Russia include a standard ‘no-claims clause’ that protects operators from having to satisfy claims brought forward by Russian and listed persons, or by persons acting through those persons or on their behalf, whenever those claims are connected with the performance of a contract or transaction affected by EU sanctions.