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The EFR notes the unprecedented scale and collaboration on new sanctions in response to the invasion of Ukraine. The deployment of sanctions is strongly supported by the financial sector and we have welcomed the cooperation with authorities to apply policy quickly and effectively. Inevitably, the application of sanctions on such a scale, with such a velocity and with so many targeted persons and entities in scope, caused challenges both on the side of the official sector as well as on the side of the private sector.

The EFR paper addresses a couple of challenges that can be avoided in the future and makes a number of recommendations:

  1. The importance and international nature of sanctions policy should be reflected in the EU’s institutional structure and international relations. This includes that the EU should lead efforts to promote coordination at international level, e.g. through Memorandums of Understanding.
  2. The European Commission should increase the transparency of legal control tests and policy.
  3. The European Commission should provide clear, detailed and timely guidance on the application of sanctions.
  4. Create a forum for information sharing between the public and private sectors.

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