On September 29, 2017, as part of Estonia’s presidency of the Council of the EU, the Estonian Foreign Ministry published an online EU sanctions map. The map seeks to present information on EU sanctions in a consolidated, user-friendly, and up-to-date way.
- clicking on a shaded country on an interactive map;
- selecting one or multiple sanctions regimes from a list;
- searching for key terms; or
- filtering by adopting authority, theme, country or measure type,
the user will be directed to an overview of the relevant sanctions regime, indicating pictorially the type of sanctions imposed by the EU (financial sanctions, arms export controls or restrictions on services, for example).
By drilling down progressively further, the user may access:
- the expiry date of the sanctions;
- a short description of the sanctions imposed in each category of sanctions;
- links to lists of the specific goods and/or persons covered by the sanctions, together with related details;
- links to the legal instruments underpinning the sanctions; and
- links to any official guidance on the application of the sanctions.
The sanctions map appears to be a powerful analytical tool. It draws together information that had previously been spread across hundreds of legal texts, purports to be up-to-date, and covers both sanctions that are agreed by the EU member states and adopted by the Council of the EU as well as sanctions imposed by the United Nations Security Council and implemented by the Council of the EU. For additional convenience, it is possible to view multiple sanctions regimes on a single page, and to export information from the map into a PDF document.
However, the sanctions map does have certain limitations:
- The sanctions map is not a complete picture: for the sake of brevity, information on exemptions, exceptions and derogations to sanctions are not included.
- No information is provided on interpretation or use of defined terms. Accordingly, it will still be necessary to refer to the underpinning legislative texts to understand the application of a given sanctions regime.
- Implementation and enforcement of sanctions are determined at the member-state level, and some member states maintain autonomous sanctions regimes, meaning it will still be necessary to locate and analyze local legal texts and guidance. The sanctions map does provide a consolidated list of competent authorities in each member state to aid further research.
- No information is provided on judicial rulings regarding EU sanctions regimes;
- It remains to be seen how quickly and diligently the sanctions map is updated, particularly after the end of the Estonian presidency of the Council of the EU.
- The sanctions map is provided strictly on a no-reliance basis, meaning neither the EU nor the Estonian Foreign Ministry accepts any responsibility for its content.
The Estonian Foreign Ministry’s press release regarding the sanctions map, including a video overview, can be found here.
Please do not hesitate to contact Matthew Fisher or any of your usual contacts at the Firm, should you have any questions.