Interesting as ever, Sam. Regarding the ‘Sanctions Union’, can you clarify what this means? Is it that the UK has in some way applied to be on the partner list and/or has tailored its own package of sanctions so as to make it eligible to be on the list? Or is it simply a unilateral EU decision and made on the basis that ‘as it happens’, UK sanctions are “substantially equivalent” to those of the EU? Conversely, does this apply the other way round i.e. does the UK recognize the equivalence of EU sanctions? Chris G
Interesting as ever, Sam. Regarding the ‘Sanctions Union’, can you clarify what this means? Is it that the UK has in some way applied to be on the partner list and/or has tailored its own package of sanctions so as to make it eligible to be on the list? Or is it simply a unilateral EU decision and made on the basis that ‘as it happens’, UK sanctions are “substantially equivalent” to those of the EU? Conversely, does this apply the other way round i.e. does the UK recognize the equivalence of EU sanctions? Chris G
Hi Chris -- "Sanctions Union" is my, slightly facetious, framing. In practice, this involves reciprocal unilateral measures based on an assessment that the other party has equivalent sanctions in place, removing the circumvention risk. The UK, in a coordinated fashion, announced the same treatment for Swiss and EU imports from 26 Feb 2024 -- https://www.gov.uk/government/publications/notice-to-importers-2953-russia-import-sanctions/guidance-on-third-country-processed-iron-and-steel-measures
Thanks, Sam, got it.