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ARTICLE · 13 AUGUST 2025

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Control-Based Restrictions Under Article 2 Of Council Regulation (EU) No 269/2014

Frangos Law
Frangos Law
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Frangos Law

Frangos Law

Founded in Larnaca, Cyprus in 2000 by Iosif Frangos, Frangos Law is a leading full-service law...

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The EU continues to adopt a stricter approach to sanctions compliance, with a growing emphasis on control-based restrictions under Article 2 of Council Regulation (EU) No 269/2014.

CyprusCompliance
Andriana Efstathiou
Andriana Efstathiou
Alexandra Oikonomou
Alexandra Oikonomou
Theofano Efstathiou
Theofano Efstathiou
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The EU continues to adopt a stricter approach to sanctions compliance, with a growing emphasis on control-based restrictions under Article 2 of Council Regulation (EU) No 269/2014. Recent guidance and enforcement practices have clarified that indirect links, such as ownership, influence, or association with designated persons or entities, may carry the same legal consequences as direct relationships.

Key Provisions of Article 2

Article 2 imposes two core obligations on EU persons and entities:

  1. Freezing of Funds and Economic Resources

"All funds and economic resources belonging to, owned, held or controlled by natural or legal persons, entities or bodies listed in Annex I shall be frozen."

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