Recent US measures directed against Iran, Cuba and Russia (North Stream 2) have
become indirectly a critical challenge for the European Union as well. As they
purport to deter economic actors under EU jurisdiction from engaging with target
countries, they have an important extraterritorial dimension, which affects EU
business and individuals and ultimately the sovereignty of the EU and its Member
States. A review of the existing sanction regimes and of the geopolitical context
reveals that other international players and the PR China in particular may follow
suit in using such measures. The study shows that extraterritorial sanctions have
important economic implications, particularly for the EU and its vulnerabilities.
Extraterritorial sanctions also raise critical questions as to their legality under
general international law, WTO law and other specific international rules. The EU is
especially affected by these measures and has taken some measures already in
response. These could be improved and additional measures could be taken, as the
policy recommendations set out.

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