This alert is an update on the position set out in our client
alert of 22 October 2012 (the "October Alert"), which can
be found
here.
Background and Regulation
On 22 December 2012, the European Council published Council
Regulation (EU) No. 1263/2012 (the
"Regulation")1. This
Regulation amends Regulation 267/2012 of 23 March 2012, and
implements the measures set out in Council Decision 2012/635/CFSP
published on 15 October 2012 (the
"Decision")1, which was the
focus of our October Alert.
As explained in the October Alert, the measures contained in the
Decision were only effective as against the governments of Member
States themselves. Now, with the publication of the Regulation,
those measures are implemented and brought
into force as against all EU persons, companies
and other entities. The Regulation also adds further detail to
those measures.
