On 14 November 2011, the EU expanded its sanctions concerning
Syria. The list of prohibited persons was expanded and prohibitions
were imposed on the dealings of the European Investment Bank.
Unlike the sanctions imposed on the Gaddafi regime (see our article
"Libya - Are Sanctions A Proper Basis for Force Majeure
Claims?", dated 20 April 2011), the current Syrian
sanctions imposed by the EU have not been mandated by the UN. Even
though they are not universally applicable, the United Kingdom has
extended the reach of the EU sanctions beyond the borders of the EU
to several territories. Furthermore, these sanctions are more
targeted than previous sanctions regimes, focusing on key
individuals, the Commercial Bank of Syria and, importantly, the
Syrian energy industry. For these reasons, European and
international companies should consider the prohibitions
carefully.
