As we mentioned in our previous update published on 2nd September (link) additional entities were added to the European Union's asset freeze list by Council Regulation (EU) 843/2011 on 24 August 2011, and at a subsequent meeting of EU foreign ministers in Poland on the 1 September 2011 further sanctions were agreed targeting Syrian's oil exports.

Council Regulation (EU) 878/2011 2 September 2011 amends the EU's original Syria Sanctions Regulation, Regulation 442/2011 9 May 2011.

To recap Council Regulation 442/2011 banned the direct and indirect sale, supply, transfer or export of goods along with related technical assistance, brokering services, financing or financial assistance to a Syrian party or for use in Syria; and a ban on making funds or economic resources available to designated Syrian parties (listed in Annex II) whose assets are frozen. The Regulation entered into force on 3 September 2011.

Subsequent Regulation 878/2011 adds a new prohibition on the purchase, transport and import, to the EU, of crude oil and certain specified "petroleum products which originate in, are located in or are being exported from Syria.

There is a special exception to this ban to allow execution of pre-existing contract obligations, provided that the execution takes place on or before 15 November 2011 and that the competent Member State authority is notified in advance.

Purchase of crude oil or specified petroleum products exported from Syria before 2 September 2011 (or before 15 November 2011 if export takes place under the previously mentioned pre-existing contract exception) is also permitted under a special exemption.

Regulation 878/2011 adds four individuals and three entities (Mada Transport, Cham Investment Group and Real Estate Bank) to the EU's existing asset freeze list (Annex II).

Banned investment

On the 21st September the EU banned European firms from making new investments in Syria's oil industry and added several new entities and two individuals to a sanctions list. The sanctions include a ban on delivery of Syrian banknotes and coins produced in the European Union, an EU official said.

The sanctions, which will take effect on Saturday (24th September) if formally approved in writing by 23rd September by the 27 EU states.

Libya Support

On the 22nd September the Council of the European Union issued a press release permitting previously frozen funds to be released for humanitarian and civilian needs, to support renewed activity in the Libyan oil and banking sectors and to assist with building a civilian government. This is in direct support of UN Security Council Resolution 2009 (2011) (adopted on 16 September 2011) which establishes a United Nations Support Mission in Libya (UNSMIL). Published on 23rd September Council Implementing Regulation (EU) No 941/2011 of 22 September 2011 implements Article 16(2) and (5) of Regulation (EU) No 204/2011 concerning restrictive measures in view of the situation in Libya.

In the same journal entry Council Decision 2011/625/CFSP of 22 September 2011 amending Decision 2011/137/CFSP concerning restrictive measures in view of the situation in Libya was published. This concerns assets held by the Central Bank of Libya, the Libyan Investment Authority, the Libyan Foreign Bank and Libya Africa Investment Portfolio. Finally, the Council lifted the asset freeze on two further companies in the oil sector, Libyan National Oil Corporation and Zuietina Oil Company

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