Applicable Law, Blocking regulations, Economic Sanctions, EU Law, European Union, Government intervention, Iran, Lex Arbitri, Lex Fori, Sanctions, United States
Sanctions vis-à-vis Blocking Measures and the Dilemma Faced by Arbitral Tribunals: Lessons Drawn From EU Blocking Regulation and U.S Extraterritorial Sanctions
Introduction The United States announced the reinstatement of sanctions on Iran in May 2018. Following that, the EU responded by revising their Blocking Regulation (Regulation 2271/96) in August 2018. The Blocking Regulation was designed to safeguard European entities from the extraterritorial reach of the U.S. sanctions. The uncertainty surrounding the scope of application and the nature of blocking…