News
Keep up with our firm’s latest news and our lawyer's appearances on several medias or talks.
Bruxelles introduit le principe d’“agent of change” en matière d’urbanisme et de logement
L’ordonnance bruxelloise du 18 juin 2026 introduisant le principe d’“agent of change” dans le Code bruxellois de l’aménagement du territoire et dans le Code bruxellois du Logement a été publiée au Moniteur belge le 26 juin 2026.
Cette ordonnance vise à mieux encadrer la cohabitation entre les nouvelles implantations ou nouveaux projets immobiliers et les activités existantes susceptibles de générer des nuisances sonores, notamment dans un contexte urbain dense.
Le principe repose sur une logique de “premier arrivé, premier servi”, sans remettre en cause le respect des arrêtés bruxellois existants relatifs au bruit. L’objectif est de faire supporter l’atténuation de l’impact acoustique au dernier arrivé.
Concrètement, le propriétaire d’une boîte de nuit qui s’installe dans un quartier devra prendre les mesures nécessaires, dans le cadre de sa demande de permis d’urbanisme visant à construire ou à réaliser une rénovation lourde, afin de prévenir ou de réduire les nuisances sonores susceptibles d’être causées au voisinage dans un rayon de 20 mètres par les activités de son établissement.
À l’inverse, le maître d’ouvrage d’un projet résidentiel ou hôtelier devra également prendre les mesures qui s’imposent, dans le cadre de sa demande de permis d’urbanisme visant à construire ou à réaliser une rénovation lourde, afin de prévenir ou de réduire les nuisances sonores qui pourraient être générées par les activités licites d’un établissement situé dans un rayon de 20 mètres autour de son projet.
L’ordonnance modifie en ce sens certaines dispositions du Code bruxellois de l’aménagement du territoire et du Code bruxellois du Logement.
Ces nouvelles règles s’appliqueront aux demandes de permis d’urbanisme introduites à partir du 1er octobre 2026.
Pour toute question à ce sujet, vous pouvez contacter :
Marie Vastmans, Séverine Perin et Fryderyk de Peslin Lachert.
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De Brusselse ordonnantie van 18 juni 2026 tot invoering van het principe “agent of change” in het Brussels Wetboek van Ruimtelijke Ordening en in de Brusselse Huisvestingscode werd op 26 juni 2026 gepubliceerd in het Belgisch Staatsblad.
Deze ordonnantie beoogt een beter evenwicht tussen nieuwe vestigingen of vastgoedprojecten en bestaande activiteiten die geluidsoverlast kunnen veroorzaken, in het bijzonder in een dichte stedelijke omgeving.
Het principe steunt op een logica van “wie eerst komt, eerst maalt”, zonder afbreuk te doen aan de naleving van de bestaande Brusselse besluiten inzake geluidsoverlast. Het doel bestaat erin de verplichting om de akoestische impact te beperken, te leggen bij de laatst aangekomen partij.
Concreet zal de eigenaar van een nachtclub die zich in een bepaalde wijk vestigt, in het kader van zijn aanvraag voor een stedenbouwkundige vergunning voor handelingen en werken die ertoe strekken een beoogde inrichting die geluidsoverlast veroorzaakt te bouwen of grondig te renoveren, de nodige maatregelen moeten nemen om de geluidsoverlast voor naburige wettige activiteiten binnen een straal van twintig meter errond te voorkomen of te verminderen.
Omgekeerd zal ook de bouwheer van een residentieel of hotelproject, in het kader van zijn aanvraag voor een stedenbouwkundige vergunning voor bouw, afbraak-wederopbouw of grondige renovatie, de nodige maatregelen moeten nemen om de geluidsoverlast van naburige wettige activiteiten van de beoogde inrichtingen die geluidsoverlast veroorzaken in een straal van twintig meter rond het project te voorkomen of te beperken.
De Brusselse ordonnantie wijzigt bepaalde bepalingen van het Brussels Wetboek van Ruimtelijke Ordening en van de Brusselse Huisvestingscode in die zin.
Deze nieuwe regels zullen van toepassing zijn op aanvragen voor stedenbouwkundige vergunningen die worden ingediend vanaf 1 oktober 2026.
Voor vragen hierover kunt u contact opnemen met:
Marie Vastmans, Séverine Perin en Fryderyk de Peslin Lachert.
EU adopts a limited set of new sanctions against Russia ahead of the expected 21st package
On 15 June 2026, the Council of the European Union adopted a new set of restrictive measures targeting Russia's full-scale invasion against Ukraine, its hybrid activities, and systematic human rights violations. The package, adopted ahead of the broader 21st sanctions package currently under discussion at COREPER II, comprises additional listings of 34 individuals and 47 entities across multiple restrictive measures regimes, namely Regulation (EU) No 269/2014, Regulation (EU) 2024/2642 and Regulation (EU) 2024/1485.
Focus on third-country designations and secondary sanctions exposure
One of the most notable aspects of the latest package is the continued expansion of EU restrictive measures beyond Russia itself. The new designations adopted under Regulation (EU) No 269/2014 target not only Russian individuals and entities, but also a growing number of companies established in third countries that are alleged to support Russia’s military, energy or logistics sectors. The listings include entities located in China, Hong Kong, the United Arab Emirates, Türkiye, Azerbaijan and Liberia.
These measures illustrate the increasingly international dimension of the EU restrictive measures regime. While EU sanctions do not formally operate through secondary sanctions in the manner of certain non-EU jurisdictions (e.g., the US), the practical consequences for third-country operators can nevertheless be significant. Once designated under Regulation (EU) No 269/2014, an entity becomes subject to the EU asset-freeze regime, meaning that EU operators must freeze any funds or economic resources belonging to it and refrain from making funds or economic resources available to it, directly or indirectly.
As a result, risk exposure to EU restrictive measures may arise even where transactions have no immediate connection to Russia. Businesses dealing with companies located in third countries should remain attentive to the possibility that such counterparties may become subject to EU restrictive measures.
Overview of the main measures
Under Regulation (EU) No 269/2014, the Council targeted Russia's military-industrial complex, imposing restrictive measures:
a. On 7 individuals and 21 entities supporting the Russian defence sector, including manufacturers and suppliers of drones and other military equipment to the Russian armed forces; and
b. On Russia's shadow fleet ecosystem, listing 2 individuals and 24 entities involved in the shipment and export of crude oil or petroleum products from Russia, which poses a threat to maritime safety and the environment.
Regulation (EU) No 269/2014 now also includes a temporary derogation for Yangzhou Yangjie Electronic Technology Co., Ltd., a Chinese company. Subject to authorization by the competent national authority, frozen funds may be released or made available where necessary to wind down pre-existing contracts by 31 December 2026 or to purchase critical components while transitioning to alternative suppliers by 16 March 2027.
2. Under Regulation (EU) 2024/2642, the Council designated 10 individuals and one entity linked to Russia’s destabilising and information manipulation activities. The listed persons include several Russian propagandists, while the designated entity is the Presidential Foundation for Cultural Initiatives.
3. Under Regulation (EU) 2024/1485, the Council designated 15 individuals and one entity in connection with the poisoning of Alexei Navalny. The listings target Russian judges, prosecutors, security and medical personnel, as well as IPJSC NTK, a company involved in facial recognition systems used against journalists and opposition activists.
Separately, the Council renewed the restrictive measures relating to the illegal annexation of Crimea and the city of Sevastopol, extending their application until 23 June 2027.
Sources : Implementing regulation - EU - 2026/1361, Regulation - EU - 2026/1336 , Implementing regulation - EU - 2026/1356, Implementing regulation - EU - 2026/1362, Council of the EU - Press release - 15 June 2026 and Coreper II - Consilium.
For more information, please contact Bruno Lebrun – Partner – b.lebrun@janson.be
CJEU confirms the broad interpretation of "material or financial support" under EU restrictive measures against Russia
On 11 June 2026, the CJEU dismissed the appeal in NSD v Council (Case C-801/24 P), thereby confirming the listing of NSD, Russia's principal central securities depository, under the EU restrictive measures against Russia.
The judgment confirms that entities may be designated not only where they directly finance the Russian State, but also where their activities play a sufficiently important facilitating role within the Russian financial system. It also confirms a broad interpretation of the derogation regime under Article 6(1) of Regulation (EU) No 269/2014.
Key takeaways
1. Broad interpretation of material or financial support
According to the CJEU, the notion of "support" encompasses not only direct financing or transfers of assets, but also assistance or facilitation capable of strengthening or enabling the actions of another party. The criterion does not distinguish between direct and indirect support and does not require a transfer of funds to the Russian State.
What matters is whether the support provided is capable, by its quantitative or qualitative significance, of supplying the Russian Government with resources or facilities enabling it to pursue the objectives targeted by the restrictive measures regime. A direct link between the support provided and Russia's actions in Ukraine is not required.
As a result, entities performing systemically important functions within the Russian financial infrastructure may be designated, even where their activities are essentially technical in nature.
2. Standard of proof
The Court further confirmed that the Council may satisfy its burden of proof through a body of sufficiently specific, precise and consistent evidence establishing a sufficient link between the listed entity and the situations targeted by the restrictive measures.
The Court acknowledged that while this evidentiary standard reflects the precautionary, temporary and reversible nature of restrictive measures, EU courts must nevertheless verify that at least one of the grounds relied upon by the Council is supported by sufficiently substantiated evidence.
3. Statement of reasons
The CJEU reiterated that the purpose of the obligation to state reasons is to enable the person concerned to understand why restrictive measures were adopted and to allow EU courts to review their legality.
It recalled that the adequacy of the statement of reasons must be assessed in light of the wording of the measure, its context and the legal framework in which it was adopted.
Therefore, the Court held that the Council had provided a sufficiently clear and specific statement of reasons. The listing measures identified both the context of their adoption and the factors justifying NSD's designation, including its role as Russia's central securities depository, its systemic importance within the Russian financial system, its access to the international financial system and its ownership structure. In those circumstances, NSD could not reasonably have been unaware of the reasons for its designation.
Whether the factors relied upon by the Council were sufficient to establish that NSD provided "material or financial support" is a separate question going to the substantive legality of the listing rather than the adequacy of the statement of reasons itself.
4. Proportionality and third-party clients
The Court rejected arguments that the listing was disproportionate because of its effects on non-designated investors whose assets are held by NSD, and thus also frozen.
It emphasised that derogation mechanisms, including those provided for in Article 6(1) of Regulation (EU) No 269/2014, remain available and must be applied by national authorities in compliance with fundamental rights. The Court also confirmed that the concept of "payment" under Article 6(1) must be interpreted broadly and encompasses the restitution of securities, not only cash transfers.
The Court further rejected the argument that the measure had become de facto permanent, stressing that restrictive measures are subject to regular review and that their continued application over a period of two years does not alter their temporary nature.
Source: EUR-Lex - 62024CJ0801 - EN - EUR-Lex.
For more information, please contact: Bruno Lebrun – Partner – b.lebrun@janson.be.
Restrictive measures : Trusts do not prevent the freezing of assets linked to a listed settlor or beneficiary (CJEU Cases C-428/24 & C-476/24 and C-483/23 of 21 May 2026)
On 21 May 2026, the CJEU clarified how assets held through trust structures must be assessed under Article 2 of Regulation (EU) No 269/2014.
The Court held that the notions of funds and economic resources "belonging to", "owned", "held" or "controlled" by a designated person are autonomous concepts of EU law and must be interpreted in light of the objectives of the EU restrictive measure. National courts must, therefore, look beyond the formal architecture of a trust and assess whether the listed person retains practical influence over, or derives economic benefit from, the relevant assets.
(See Cases C-428/24 and C-476/24, and Case C-483/23).
CJEU decides substance over form
The Court rejected a purely formal analysis based on trust documentation. Whether the assets held in trust must be frozen depends on a factual assessment of all relevant circumstances, including:
the powers effectively retained by the listed person over the trust;
the degree of influence exercised over trustees, protectors or trust administrators;
the economic benefit derived from the trust assets;
where companies are contributed to the trust: the powers of their directors and their links to the listed person;
the timing and purpose of any restructuring undertaken before or after designation.
The Court emphasised that trust-law cannot undermine the effectiveness of EU restrictive measures or facilitate circumvention. Unnecessarily complex structures are themselves treated as an indicator of control.
Beneficiary trusts: compliance clauses are not decisive
In joint cases C-428/24 and C-476/24, the trusts were irrevocable discretionary trusts governed by Bermuda law. The trust instruments contained clauses prohibiting distributions to the beneficiary while that person remained subject to EU restrictive measures. The Court held that such clauses cannot be decisive seeing that trust deeds are private documents, not subject to any obligation of public disclosure, that their terms can be amended at any time and that unilateral commitments can be revoked.
The existence of formal restrictions on distribution does not eliminate the need to determine whether the designated beneficiary continues, in practice, to benefit from or exercise influence over the trust assets. Nor does the prohibition on making funds available under Article 2(2) of Regulation (EU) No 269/2014 replace the separate obligation to freeze assets under Article 2(1) of Regulation (EU) No 269/2014.
Settlor trusts: exclusion from the beneficiary class is not conclusive
In case C-483/23, the designated settlor had been removed from the class of beneficiaries before his listing. The Court, nevertheless, held that this fact alone cannot preclude a finding that the assets remain attributable to the settlor for the purposes of Article 2(1) of Regulation (EU) No 269/2014.
National courts must examine whether the settlor continues to retain powers capable of conferring influence over the trust structure, including powers relating to trustees, protectors, beneficiaries, or the administration of trust assets. In this respect, the Court noted that powers such as the power to revoke the trust, to give binding instructions to the trustee, and to appoint or remove trustees and protectors are indicators of continued control whether or not they are expressly mentioned in the trust deed, and may subsist even after formal exclusion from the beneficiary class.
These judgments confirm that national authorities enforcing EU restrictive measures and national courts must assess trust arrangements on the basis of economic reality rather than formal legal qualification.
Source : EUR-Lex - 62024CJ0428 - EN - EUR-Lex and EUR-Lex - 62023CJ0483 - EN - EUR-Lex.
For more information, please contact: Bruno Lebrun – Partner – b.lebrun@janson.be.
THE EU COMMISSION’S INVESTIGATIVE POWERS UNDER THE FSR: THE CONSECRATION OF THE EU’S EXTRATERRITORIAL JURISDICTION ?
EU–China tensions escalate over the EU Foreign Subsidies Regulation
Recent developments surrounding the European Commission’s enforcement of the Foreign Subsidies Regulation (“FSR”) have reignited debates regarding the extraterritorial reach of EU regulatory powers and the escalating legal tensions between the European Union (“EU) and China.
The controversy notably arises in the context of the Commission’s ongoing investigation into Chinese company Nuctech under the FSR framework. On 15 May 2026, Chinese authorities publicly criticised the investigation, arguing that the Commission is using the FSR as a unilateral instrument to target Chinese undertakings and requesting information extending beyond the EU’s territorial jurisdiction. In particular, China objected to the Commission’s requests for information addressed to Chinese financial institutions and concerning data located in China, characterising such measures as unlawful exercises of extraterritorial jurisdiction.
From the Commission’s perspective, however, the FSR constitutes a legitimate internal market instrument aimed at addressing distortions of competition caused by foreign subsidies granted to companies active within the EU. The Commission maintains that its investigative powers — including requests for information addressed to non-EU entities — are necessary to ensure the effectiveness of the Regulation and remain consistent with EU law and international obligations. In particular, the Commission considered that the requests for information addressed to Chinese undertakings in the context of the Nuctech investigation constitute “standard measures”.
These developments arguably confirm concerns already raised when the Commission published its first White Paper on foreign subsidies in 2020. At the time, it was foreseeable that such an instrument would significantly affect the normal investment and business operations of Chinese undertakings and financial institutions active within the EU, particularly given the broad investigative powers conferred upon the Commission and the extensive disclosure obligations that may be imposed on foreign operators.
The FSR as a vehicle for the EU’s extraterritorial jurisdiction?
The legal debate raised by the Nuctech investigation goes beyond the sole application of the FSR and touches upon a broader question: to what extent may the EU exercise regulatory and investigative powers over conduct, entities or information located outside its territory?
From an international public law perspective, jurisdiction is traditionally grounded on the territoriality. However, contemporary economic regulation increasingly relies on forms of “qualified extraterritoriality”, particularly where foreign conduct produces effects within a domestic market. In that respect, the EU has traditionally applied an “effects-based” approach in several areas of law, notably competition law, data protection and financial regulation.
The FSR endorses that approach. Although formally designed to regulate distortions affecting the EU internal market, its practical application necessarily extends beyond EU borders. Indeed, the very object of the Regulation concerns financial contributions granted by third countries, often involving non-EU parent companies, foreign state-owned entities and financial institutions located outside the Union.
Under the FSR, the Commission may request extensive information concerning foreign subsidies, financing arrangements and corporate structures from undertakings established outside the EU. While the Regulation itself does not provide for direct enforcement powers abroad comparable to those of national authorities exercising territorial jurisdiction, it nevertheless creates significant pressure on foreign operators to cooperate. Failure to comply may expose companies to substantial fines, adverse inferences or restrictions regarding access to the EU market.
The legal justification advanced by the Commission remains on the existence of a sufficient territorial nexus with the EU internal market. In essence, the Commission’s position is that companies benefiting from access to the EU market may legitimately be required to disclose information necessary to assess whether foreign subsidies distort competition within the EU.
Whether such an approach constitutes a legitimate application of the “effects doctrine” or an excessive extension of EU jurisdiction remains open to debate. Critics argue that the breadth of the Commission’s investigative powers — particularly where requests concern information located entirely outside the EU or involve non-EU financial institutions — risks blurring the traditional limits of territorial jurisdiction and creating potential conflicts with foreign blocking statutes, data protection regimes or national sovereignty interests.
Towards an increasingly assertive EU economic governance model
This dispute highlights the broader legal and geopolitical implications of the FSR, whose enforcement increasingly intersects with questions of sovereignty, international comity and regulatory overlap. It also reflects the EU’s broader shift towards a more assertive economic governance model, notably in areas relating to economic security, strategic autonomy and competitive neutrality.
As the Commission continues to expand its enforcement practice under the FSR, multinational companies — particularly those benefiting from direct or indirect financial support from a foreign state — should closely monitor the evolving regulatory landscape and carefully assess the implications of the Regulation for cross-border transactions, public procurement procedures and internal compliance mechanisms.
See Regulation (EU) 2022/2560 of the European Parliament and of the Council of 14 December 2022 on foreign subsidies distorting the internal market (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02022R2560-20221223).
For more information, please contact Bruno Lebrun – Partner – b.lebrun@janson.be.
EU Commission proposes “EU Inc.” : a new optional EU-wide corporate regime
A landmark legislative proposal introduces an optional, fully digital, EU-wide corporate framework designed to simplify the creation and scaling of businesses across the EU. This initiative forms the cornerstone of the EU’s forthcoming “28th regime for companies”, aimed at enhancing competitiveness and reducing legal fragmentation within the Single Market.
EU Inc. represents a significant shift in EU company law as it offers a single, harmonised set of corporate rules that businesses may opt into, instead of navigating the complexities of 27 national legal systems and over 60 company forms. The proposal is structured as an EU Regulation and is intended to:
Facilitate rapid company formation (within 48 hours)
Enable fully digital corporate operations
Reduce administrative burdens and costs
Improve access to capital and talent
Strengthen the EU’s attractiveness for startups and scale-ups
Core elements of EU Inc.
Fast and cost-efficient incorporation: EU Inc. companies could be established within 48 hours, at a cost below €100, and without minimum share capital requirements.
Single EU-level digital interface: companies will submit information once via an interconnected EU system linking national registers, with a future central EU register planned.
Fully digital lifecycle: corporate governance, filings, shareholder meetings, financing operations, and even liquidation procedures will be conducted digitally by default.
Simplified insolvency and liquidation: startups benefit from streamlined winding-up procedures, reducing time, cost, and stigma associated with business failure.
Enhanced investment framework: the proposal removes formal barriers such as mandatory intermediaries for share transfers and enables flexible share structures (e.g., multiple voting rights), improving investor appeal.
Talent attraction mechanisms: EU-wide employee stock option plans will be introduced, with taxation deferred until realisation, enhancing competitiveness in talent acquisition.
Freedom of establishment across the EU: companies may choose their Member State of incorporation while benefiting from uniform rules across the EU.
Safeguards against abuse: national labour, social, and tax laws remain fully applicable, ensuring that EU Inc. cannot be used to circumvent employee protections or regulatory standards.
Strategic Context
The initiative forms part of the EU’s broader competitiveness agenda, as highlighted in the Draghi Report on EU competitiveness. It sits within the wider “28th regime” framework developed by the EU Commission, which combines EU Inc. with a set of complementary measures to support innovative companies across the Single Market.
These include initiatives to enhance access to capital (notably under the Savings and Investment Union and venture capital reforms), advance tax simplification (including BEFIT and the Head Office Tax system), accelerate digitalisation (in particular through the European Business Wallet), facilitate labour mobility and cross-border telework, and promote a more consistent legal environment, including through specialised judicial chambers or courts and common definitions for innovative companies.
In this context, EU Inc. contributes indirectly to the development of the Capital Markets Union by reducing legal fragmentation and standardising the corporate framework, thereby enhancing the scalability and attractiveness of EU companies for cross-border investment. It does not, however, harmonise capital markets rules (e.g. listing requirements, securities law or investor protection), which remain governed by separate EU initiatives.
EU Inc. marks a potentially transformative development in EU company law, aiming to reduce fragmentation and unlock the full potential of the Single Market. While optional, its practical advantages could drive significant uptake, particularly among innovative and high-growth companies.
Businesses operating in or entering the EU should monitor legislative developments closely and begin evaluating the strategic opportunities and implications of this new regime.
Next Steps
The proposal is now being reviewed by the EU Parliament and the Council. The Commission seeks political agreement by the end of 2026.
Sources : Commission presents proposal for EU Inc.; Questions & answers ; Factsheet: Proposal for an EU Inc. corporate legal framework ; EU Inc.: A new harmonised corporate legal regime ; Communication: towards a EU Inc. for EU companies ; Proposal for an EU Inc. corporate legal framework ; Impact assessment for EU Inc. corporate legal framework ; Recommendation to harmonise the definition of innovative companies, startups and high-growth scaleups ; EU Startup and Scaleup Strategy - Research and innovation.
For more information, please contact Bruno Lebrun – Partner – b.lebrun@janson.be.
EU sanctions: two key CJEU judgments for companies and financial institutions
EU Restrictive Measures
CJEU clarifies the broad scope of asset freezes and the notion of control
On 12 March 2026, the CJEU delivered two important judgments clarifying the scope of the EU restrictive measures and their implications for companies and financial institutions.
Taken together, these judgments confirm the CJEU’s broad and functional interpretation of EU restrictive measures whose purpose is also to prevent sanctioned persons from indirectly benefiting from assets or exercising influence on corporate structures.
Asset freezes may affect shareholder rights (SBK Art v Fortenova Group STAK Stichting; C-465/24)
The SBK Art judgment confirms that asset freezes may affect the exercise of shareholder rights where their exercise would allow a sanctioned person to obtain economic benefit from, or influence the use of, frozen assets.
In this case, a sanctioned shareholder holding certificates linked to shares in Fortenova Group challenged its exclusion from a meeting of certificate holders.
The question referred to the Court was whether the freezing of funds under EU restrictive measures prevents a sanctioned shareholder from exercising voting and participation rights attached to shares or share certificates.
The CJEU confirmed that the concept of “funds” and “economic resources” must be interpreted broadly in order to ensure the effectiveness of EU sanctions. Therefore, where the exercise of voting rights may enable a sanctioned person to influence corporate decisions or derive economic benefit from frozen assets, those rights may fall within the scope of the freezing obligation.
Presumption of control over companies partly owned by sanctioned persons (EM System; C-84/24)
This case concerned a Lithuanian company whose funds were frozen after one of its shareholders holding 50% of its capital, was added to the list of sanctioned entities in the context of the EU restrictive measures targeting Belarus (see Council Regulation (EC) No 765/2006).
Although the company EM System itself was not designated, some financial institutions considered that its funds should be frozen because the company could be regarded as owned or controlled by a listed person.
The CJEU confirmed that:
- a 50% shareholding held by a sanctioned person may create a presumption of control; and
- the funds of the company could, therefore, be treated as subject to the asset-freezing obligation.
But, the Court also clarified that this presumption is rebuttable. A non-listed entity must have the opportunity to demonstrate that its funds are not in fact controlled by the listed person.
Key Findings
These judgments provide important clarification on the practical implementation of EU restrictive measures:
A broad and functional approach to restrictive measures: the restrictive measures must be interpreted in light of their anti-circumvention objective, covering situations where sanctioned persons could otherwise retain influence or economic benefit through corporate structures.
Impact on corporate governance: sanctioned shareholders may be prevented from exercising certain corporate rights, including voting or participation rights, where their exercise could undermine the effectiveness of asset freezes.
Increased compliance scrutiny of ownership structures: financial institutions and companies should carefully assess shareholding structures and governance rights, particularly where sanctioned persons hold significant minority stakes.
Litigation: the presumption of control is rebuttable, preserving the right of affected entities to demonstrate the absence of control.
These rulings also illustrate the CJEU’s increasingly strict approach to preventing circumvention of EU sanctions.
Sources : EUR-Lex - 62024CJ0465 - EN - EUR-Lex and EUR-Lex - 62024CJ0084 - EN - EUR-Lex.
For more information, please contact Bruno Lebrun – Partner – b.lebrun@janson.be.
An unforgettable evening marking Janson’s 75th anniversary (pictures)
What better way to celebrate our 75th anniversary than by bringing together our clients, partners and colleagues for an evening built around great conversations, a beautiful venue and the exceptional voice of Emma Bale.
The atmosphere was warm, the setting was remarkable and the energy in the room reminded us why these connections matter.
We are grateful to everyone who joined us and made this anniversary so meaningful. Here is a look back at some of the highlights captured that night.
EU Restrictive Measures Update — The General Court confirms a broad reach against indirect supporters of Russia’s War in Ukraine (Case T-150/24, 25 February 2026)
On 25 February 2026, the General Court of the European Union (Case T-150/24) confirmed the legality of restrictive measures imposed on AlfaStrakhovanie, one of Russia’s largest insurance undertakings and subsidiary of the Alfa Group. On 18 December 2023, AlfaStrakhovanie had been listed under Annex I of Regulation (EU) No 269/2014 because it provided indirect material and financial support to the Russian government in the context of Russia’s war of aggression against Ukraine.
The General Court clarifies the contours of Criterion (f), which targets persons and entities providing material or financial support to the Russian government, and to further consolidate its post-2022 sanctions jurisprudence.
A broad interpretation of “material or financial support”
The Council designation of a person or entity under the sanction list must rely on one listing criterion set out in Article 3(1) of Regulation (EU) No 269/2014. AlfaStrakhovanie was designated on the basis of criterion (f), which covers “natural or legal persons, entities or bodies supporting, materially or financially, or benefitting from the Government of the Russian Federation, which is responsible for the annexation of Crimea and the destabilisation of Ukraine.”
The General Court has confirmed that criterion (f) does not require the existence of a direct link between the conduct relied upon and military operations carried out in Ukraine. It is sufficient that the activities in question objectively benefit state bodies or entities linked to the military effort, or otherwise contribute to the mobilisation or functioning of the resources of the Russian State.
The General Court has thus accepted that the provision of insurance services to the Russian National Guard, the Ministry of Defence, or companies forming part of the military-industrial complex may amount to material or financial support within the meaning of criterion (f). This may be the case even where such services are required under domestic law or correspond to ordinary commercial activities carried out in the course of business.
Thus, where such activities play a meaningful role in sustaining or enabling state or military structures, they may legitimately be taken into account for the purposes of designation under Regulation (EU) No 269/2014.
Reliance on indirect and publicly available evidence
The General Court held that the Council may rely on a consistent body of indirect evidence drawn from open sources, including press investigations, corporate disclosures, and publicly accessible procurement or financial data.
It rejected the argument that a listing decision must be based exclusively on prior judicial or administrative findings, emphasising instead that the decisive issue is whether the evidence relied upon, assessed as a whole, is sufficiently precise, reliable, and mutually corroborative. This confirms the existence of a flexible evidentiary threshold, particularly in a context where direct access to information is inherently limited.
Consistently with other judgments delivered in recent years (e.g., Timchenko, Case T-498/22) the EU Courts have reiterated that the factual situation in Russia and Ukraine significantly restricts access to primary sources of information. Therefore, says the General Court, the Council cannot be required to identify or rely systematically on original or first-hand sources, provided that the information used is credible, convergent, and capable of substantiating the conclusions drawn.
Proportionality and fundamental rights
In line with settled case law, the General Court reaffirmed that EU restrictive measures are preventive in nature, temporary, and reversible. The resulting interference with fundamental rights, including the freedom to conduct a business and the right to property, was considered proportionate in light of the overarching objective of exerting pressure on the Russian Federation to cease its aggression against Ukraine.
The General Court also attached importance to the existence of derogation mechanisms within the sanctions framework. These mechanisms are intended to mitigate the potentially excessive effects of asset-freeze measures and to allow access to frozen assets for essential needs or for specifically authorised purposes.
That said, the proportionality assessment remains contingent on the effective availability of such derogations in practice. Recent experience suggests that derogations are granted sparingly and often subject to restrictive interpretation, particularly where sanctioned entities are concerned. This raises questions as to whether the mitigating function attributed to derogation mechanisms by the EU Courts is fully realised de facto, and whether, in certain cases, the cumulative effects of restrictive measures may extend beyond what is strictly necessary to achieve their preventive objectives.
Conclusion
The AlfaStrakhovanie judgment shows clearly that EU restrictive measures now focuses more on effects than on intentions. By accepting that routine, and even mandatory, commercial services may amount to “material or financial support” when they objectively benefit the Russian state, the General Court lowers the threshold for exposure to listing under criterion (f). The decisive question is no longer whether an operator intended to support the war effort, nor whether its activities are intrinsically military in nature, but whether those activities contribute, even indirectly, to the functioning or resourcing of state structures engaged in the conflict.
This approach undeniably strengthens the preventive and deterrent function of EU restrictive measures. At the same time, it introduces a degree of legal uncertainty for economic operators, particularly in sectors such as insurance, finance, logistics or infrastructure services, where interaction with state-linked counterparties may be unavoidable.
The judgment of Case T-150/24 is available on : EUR-Lex - 62024TJ0150 - EN - EUR-Lex
For more information, please contact :
Bruno Lebrun – Partner – b.lebrun@janson.be
Lexology In-Depth: Private Competition Enforcement - Edition 19
Our EU & Competition Law Department has contributed to the Belgian chapter in “In-Depth: Private Competition Enforcement” by Lexology.
Bruno Lebrun and his team provide an overview of most recent trends in private competition law enforcement in Belgium, including key procedural aspects and developments shaping the litigation practice.
Interested in this topic and the latest evolutions ? Have a look to the article via this link: https://www.lexology.com/indepth/private-competition-enforcement/belgium
EU sanctions: Company board may include Russian administrators if they do not control the company (CJEU, 12 February 2026, C-313/24)
Background: An Italian company, Scudieri International, was awarded a public contract by Italian authorities. Two of its three board members were Russian nationals, one of whom was also the sole administrator of the parent company. A competitor challenged the award, arguing it violated EU restrictive measures.
Question referred to the CJEU: Does the prohibition apply to an EU-based company, whose shareholders are not Russian, but whose board members are Russian nationals holding key positions?
On 12 February 2026, the Court of Justice of the European Union (“CJEU”) decided that the mere presence of Russian board members is not sufficient to trigger the prohibition of Article 5 k(1)(c). The latter would only apply if it is demonstrated that the board members effectively control the company, creating a plausible risk that public funds could be diverted to the Russian economy.
Key Criteria:
Comprehensive reviewby authorities: ownership structure, personal/professional links, past coordination with sanctioned entities, etc.
Risk of diversion: Evidence must show that public funds could be used to finance Russia’s aggression in Ukraine.
No presumption: Russian nationality of board members alone does not create a prohibition.
Why this judgment matters
Enhanced Legal Certainty: Public authorities and economic operators have clear guidelines on how to assess the risk of circumvention.
Case-by-case Assessment: The CJEU requires a concrete assessment based on concrete evidence (effective control, risk of diversion).
Impact on Public Procurement: Contracting authorities must document their assessment of links between bidders and sanctioned entities, using objective criteria (control structure, track record, etc.).
Political Signal: The ruling reaffirms that sanctions aim to deprive Russia from financial resources for its aggression in Ukraine, without unduly penalizing legitimate EU businesses.
This ruling is an interesting signal as it provides a clear roadmap for public and private actors, while ensuring that efforts to prevent sanctions circumvention remain proportionate and evidence-based.
Sources : EUR-Lex - 62024CJ0313 - EN - EUR-Lex
For more information, please contact Bruno Lebrun – Partner – b.lebrun@janson.be
The Digital Networks Act: a new regulatory framework to boost the EU connectivity
What is the Digital Networks Act?
The Digital Networks Act (“DNA”) is the EU Commission’s proposed reform of the EU framework governing electronic communications networks and services. Adopted by the EU Commission on 21 January 2026, the DNA is designed to replace and consolidate the current regulatory architecture, notably the 2018 European Electronic Communications Code (EECC), into a single, directly applicable Regulation.
The DNA promotes a modern, simplified and more harmonised legal framework capable of supporting the deployment of high-capacity digital infrastructure across the EU. By facilitating investment in advanced fibre, mobile, satellite and cloud-enabled networks, the DNA places the connectivity as a core enabler of Europe’s digital economy, including the development of artificial intelligence, cloud computing and other data-intensive technologies.
Context of the proposal and rationale
The proposal responds to long-standing structural challenges in the EU electronic communications sector. Despite previous harmonisation efforts, the EU market remains fragmented into 27 national regimes, limiting to operate cross-border. This fragmentation has constrained investment capacity and slowed the deployment of next-generation networks.
The EU Commission’s initiative builds on extensive policy reflection and stakeholder input, notably the 2024 White Paper “How to master Europe’s digital infrastructure needs?”, the 2025 Call for Evidence, and together with the Draghi and Letta reports. These assessments highlighted the urgent need for regulatory simplification, stronger investment incentives and a more integrated Single Market for connectivity.
The proposal is also shaped by the broader geopolitical and security context. Increased exposure to cyber threats, foreign interference and supply chain dependencies, as well as the need for crisis readiness, have underscored the strategic importance of resilient and secure digital infrastructure at EU level.
Objectives of the DNA
The DNA pursues three interrelated objectives:
Strengthening competitiveness and investment: The DNA aims to enhance the competitiveness of the EU connectivity sector by creating predictable and investment-friendly conditions for the rollout of advanced digital infrastructures, including fibre, 5G and future 6G networks;
Consolidating the Single Market for connectivity: The DNA seeks to facilitate cross-border provision of networks and services, by removing regulatory barriers and harmonising authorisation regimes;
Enhancing resilience and preparedness: The DNA contributes to promote cooperation, reduce strategic dependencies and reinforce the resilience of digital networks against crises, natural disasters and security threats.
Key measures and expected benefits
To achieve these objectives, the DNA introduces a series of structural reforms.
A cornerstone of the proposal is the creation of conditions for a Single Market for connectivity authorisation, including the option of a Single Passport system allowing providers to operate across the EU with notification in only one Member State. In parallel, the DNA establishes an EU-level satellite spectrum authorisation, facilitating pan-European satellite services.
The DNA also modernises spectrum management by promoting longer licence durations, default renewability of licences to enhance predictability, and wider use of spectrum sharing to ensure efficient utilisation and lower entry barriers for new providers.
To support the transition to future-proof infrastructure, the DNA introduces mandatory national transition plans for the phased switch-off of copper networks and the move to full-fibre and other advanced networks between 2030 and 2035, accompanied by safeguards to protect consumers and ensure service continuity.
From a regulatory perspective, the DNA significantly reduces administrative and compliance burdens, particularly in business-to-business relations, while maintaining a high level of consumer protection. It also introduces mechanisms to clarify the application of Open Internet rules to innovative services and establishes a voluntary cooperation framework on issues such as IP interconnection and traffic efficiency.
In terms of security, the DNA strengthens network resilience through an EU-level Preparedness Plan for Digital Infrastructures, measures to reduce dependencies in the connectivity ecosystem, and security-focused criteria for pan-European satellite communications.
Governance System
The DNA also revises the governance framework for EU connectivity regulation.
The Radio Spectrum Policy Group (RSPG) will be transformed into a formal EU body, the Radio Spectrum Policy Body (RSPB), reinforcing its role in shaping spectrum policy at EU level.
The Body of European Regulators for Electronic Communications (BEREC) will remain a central actor and will be entrusted with additional responsibilities, including the development of guidelines under the Single Passport authorisation regime, measures to protect end-users against fraud, and contributions to the Union Preparedness Plan.
To reflect these expanded tasks, the current BEREC support office will be renamed the Office for Digital Networks (ODN), supporting both BEREC and the new RSPB.
Next steps
The DNA proposal will now be examined by the EU Parliament and the Council of the EU under the ordinary legislative procedure. If adopted, it will mark a significant shift in EU connectivity regulation, laying the foundations for a more integrated, resilient and competitive digital infrastructure ecosystem.
By addressing long-standing market fragmentation, accelerating the transition to advanced networks and reinforcing security and preparedness, the DNA positions connectivity as a strategic pillar of EU’s digital and economic future.
See Proposal for a Regulation for the Digital Networks Act (DNA) | Shaping Europe’s digital future
For further information, please contact :
Bruno Lebrun - Partner - b.lebrun@janson.be
Wafa Lachguer – Associate - w.lachguer@janson.be
From Threat to Action: How the EU Could Fight Back Against Trump’s Economic Pressure
On 18 January 2026, French President Emmanuel Macron announced that he would request the activation of the EU’s Anti-Coercion Instrument in response to recent threats of unilateral tariff increases by the United States. These developments have brought renewed attention to Regulation (EU) 2023/2675 on the protection of the Union and its Member States from economic coercion by third countries.
Adopted on 22 November 2023 and in force since 27 December 2023, Regulation (EU) 2023/2675 establishes a legal framework enabling the EU to respond when a third country applies, or threatens to apply, measures affecting trade or investment in order to influence the sovereign decisions of the EU or its Member States. The instrument, often referred to as the EU’s “trade bazooka”, is conceived primarily as a deterrent mechanism, aimed at preventing coercive conduct before retaliatory measures become necessary.
Economic coercion, within the meaning of the Regulation, occurs where a third country interferes with legitimate EU or Member State choices through economic pressure. The assessment of such coercion involves a detailed examination by the European Commission, taking into account the severity, duration and impact of the measures concerned, as well as their effect on EU sovereignty and whether the coercing country has acted in good faith.
Where economic coercion is established, the EU is required to first seek a resolution through dialogue. Only if such efforts fail may the EU adopt proportionate countermeasures, provided that these are necessary to safeguard the Union’s interests and are consistent with its overall policy objectives. Possible responses include trade restrictions, measures affecting services or investment, or limitations on access to EU public procurement and capital markets.
To date, the Anti-Coercion Instrument has never been applied. However, recent geopolitical tensions raise the possibility of a first-ever activation of this mechanism, thereby testing the EU’s capacity to act autonomously and in a coordinated manner in the face of external economic pressure.
In this article, Bruno Lebrun, Partner, analyses the scope and functioning of Regulation (EU) 2023/2675, the conditions under which economic coercion may be established, and the range of response measures available to the EU. He also considers the practical and political implications of a potential first application of the Anti-Coercion Instrument.
The EU Commission publishes Guidelines on the Foreign Subsidies Regulation
The EU Commission has published its long-awaited Guidelines on the application of the EU Foreign Subsidies Regulation (“FSR Guidelines”), marking a significant step in the consolidation of the EU’s new framework to address distortions caused by foreign subsidies in the EU internal market. The FSR Guidelines, which the EU Commission was required to adopt by 13 January 2026, aim to enhance legal certainty, transparency and predictability for companies active in the EU.
They follow extensive consultations with Member States and stakeholders. In particular, the EU Commission published draft FSR Guidelines on 18 July 2025 and launched a public call for feedback, reflecting the importance and sensitivity of the new regime.
The final FSR Guidelines now provide detailed insight into how the Commission intends to enforce the FSR in practice.
Assessment of distortions under Articles 4(1) and 27 FSR
The FSR Guidelines confirm that a foreign subsidy is distortive where it is liable to improve the competitive position of an undertaking in the internal market and, as a result, actually or potentially negatively affects competition. The EU Commission will apply a structured analysis, distinguishing between targeted and non-targeted foreign subsidies, and paying particular attention to the risk of cross-subsidisation of EU activities.
In the context of public procurement, the FSR Guidelines clarify that the EU Commission’s assessment will focus on whether a foreign subsidy enabled an economic operator to submit an unduly advantageous tender. This involves examining how the bid was designed, whether it is unduly favourable compared to competing offers or the contracting authority’s estimates, and whether the advantage can be attributed, to an appreciable extent, to the foreign subsidy rather than to legitimate efficiency or commercial factors.
Clarification of the balancing test under Article 6 FSR
The FSR Guidelines provide detailed guidance on the balancing of negative and positive effects of a foreign subsidy. Only positive effects that are specific to the subsidy under assessment will be taken into account, including effects linked to the development of the subsidised activity or to broader EU policy objectives. The EU Commission will assess whether such positive effects could be achieved without the distortion and will decide whether to clear the subsidy, accept commitments, or impose redressive measures.
Call-in powers for concentrations and public procurement
The FSR Guidelines clarify the conditions under which the EU Commission may request the prior notification of non-notifiable concentrations or public procurement procedures under Articles 21(5) and 29(8) FSR. The EU Commission will assess, inter alia, the impact in the Union, the strategic nature of the activity, and the likelihood of a distortion, while also recognising specific safe harbours, notably for low-value procurement procedures and limited foreign subsidies.
Enforcement context and recent cases
The publication of the FSR Guidelines comes shortly after a number of high-profile enforcement actions that illustrate the Commission’s increasingly assertive use of the FSR.
In December 2025, the EU Commission announced the opening of an in-depth ex officio investigation into Nuctech’s activities in the threat detection systems sector. The investigation, initiated following inspections carried out in April 2024, focuses on alleged foreign subsidies granted by the People’s Republic of China, including grants, preferential tax measures and preferential financing. The EU Commission raised preliminary concerns that these measures may have enabled Nuctech to offer prices and conditions in public tenders that could not be reasonably matched by competitors, thereby distorting competition in the internal market.
Earlier, in November 2025, the EU Commission conditionally approved the acquisition of Covestro by ADNOC under the FSR, subject to compliance with binding commitments. The EU Commission found that foreign subsidies granted by the UAE (including an unlimited State guarantee, a committed capital increase and advantageous tax measures) were liable to distort competition both in the acquisition process and in the post-transaction activities of the merged entity.
Conclusion
Taken together, the FSR Guidelines and the EU Commission’s recent decisional practice confirm that the FSR has entered a fully operational and enforcement-driven phase. Foreign companies involved in acquisitions, public procurement or other economic activities in the EU must now carefully assess their exposure to foreign financial contributions and anticipate enhanced scrutiny. Moreover, EU companies may pay great attention to the nature and origin of the capitalization of their foreign competitors.
For further information, please contact :
Bruno Lebrun - Partner - b.lebrun@janson.be
Wafa Lachguer – Associate - w.lachguer@janson.be
EU Plans Tougher Oversight of Inbound Investments Under New Economic-Security Roadmap
The EU Commission has unveiled a new “Strengthening EU Economic Security” roadmap that significantly tightens scrutiny of foreign investments into the bloc.
Key developments:
Portfolio investments to face monitoring for the first time:
The EU plans to work with national supervisors to track non-controlling stakes taken by hedge funds, asset managers and other investors in sectors deemed high-risk. These investments are currently outside the EU’s FDI screening rules.
Towards a stronger, more harmonized FDI framework:
As part of the ongoing review of the 2020 regime, the Commission seeks binding obligations, expanded powers, and greater coordination among member states.
Several governments, however, resist Brussels’ push for broader coverage and want to preserve national control.
Technology-transfer conditions for sensitive sectors:
The roadmap signals the introduction of technology-transfer requirements for deals involving advanced or strategic technologies, potentially including the battery-electric vehicle sector.
Objective: ensure know-how and value creation remain within the EU and avoid creating strategic dependencies.
Use of the Foreign Subsidies Regulation for security risks:
Although designed to counter market distortions, the FSR will be deployed where foreign state support creates economic-security concerns, with the Commission pledging full use of the tool.
Overall impact:
The initiative marks a substantial tightening of the EU’s investment-screening posture, extending oversight beyond traditional FDI and linking investment controls more explicitly to economic-security priorities.
Sources :
For more information, please contact Bruno Lebrun – Partner – b.lebrun@janson.be
EU Commission unveils proposals to use the frozen funds of the Russian Central Bank
On 3 December 2025, the EU Commission published several proposals for regulations outlining two possible mechanisms to support Ukraine's financial needs.
These proposals will be discussed during the next European Council on 18-19 December 2025 which aims at a clear commitment on the way forward.
These proposals include a number of safeguards designed to protect Member States and financial institutions holding the frozen assets of the Russian Central Bank.
These two proposed solutions are :
the use of the UE budget to underpin a loan to Ukraine; and
the creation of a “reparation loan” allowing the EU Commission to borrow cash balances from EU financial institutions holding immobilised assets or reserves of the Russian Central Bank, or assets held for its benefit (or for the benefit of any legal person, entity or body acting on behalf of, or at the direction of the Russian Central Bank, such as the Russian National Wealth Fund). This proposal does not concern, other frozen funds.
There is no legal basis allowing the use of Russian frozen funds belonging to other Russian entities or individuals.
Sources :
For more information, please contact :
Bruno Lebrun – Partner – b.lebrun@janson.be
Cédric Alter – Partner – c.alter@janson.be
Donations in the Brussels-Capital Region: new rules as of January 1, 2026
As of January 1, 2026, the lookback period for unregistered donations will be extended from 3 to 5 years in the Brussels-Capital Region.
This lookback period applies to all unregistered movable donations, i.e., all donations for which no donation duties have been paid. This includes, for example, bank transfers (account-to-account transfers) or manual gifts.
Currently, failure to pay donation duties means that if the donor dies within 3 years of the donation, the donation is retroactively included in the inheritance tax return and becomes subject to inheritance tax.
For donations made as of January 1, 2026, this waiting period will be extended to 5 years (Ordinance of the Brussels-Capital Region of July 17, 2025 amending various provisions of the Code of Inheritance Duties and the Code of Registration, Mortgage and Court Fees, Official Gazette, July 24, 2025).
By doing so, the Brussels-Capital Region aligns itself with the regime already applicable in the Flemish Region (since 2012) and in the Walloon Region (since 2022).
It should be noted that the criterion for determining which legislation applies to a donation is the tax residence of the donor during the five years preceding the donation.
It is therefore still possible to make unregistered donations before January 1, 2026, which will benefit from a 3-year lookback period.
However, donors who do not want to take risks regarding this lookback period can opt for registered donations, which are subject to donation duties at a favorable rate (compared to inheritance tax), namely 3% or 7% in the Brussels-Capital Region, depending on whether the donation is made directly between spouses, legal cohabitants, or ascendants and descendants in the first case, or between other persons in the second case.
It should also be stressed that a registered donation allows much greater legal certainty regarding the conditions attached to the donation, particularly through mechanisms to maintain control over the donated assets (such as a usufruct reservation, a temporary inalienability clause, or a management clause).
Game-changing EU Court of Justice judgment rocks the football world and reaffirms the principle of EU law’s effectiveness
On 1 August 2025, the Court of Justice of the European Union delivered a landmark ruling in Case C‑600/23 (RFC Seraing v. FIFA), confirming that clubs, athletes, and other sports stakeholders in the EU must have access to effective judicial review of arbitral awards issued by the Court of Arbitration for Sport (CAS). The Court held that national courts must be able to examine such awards for compliance with EU law, even when confirmed by non-EU courts, and that arbitration cannot override the fundamental rights guaranteed by EU law.
This judgment stems from a dispute involving the Belgian club RFC Seraing, sanctioned by FIFA for third‑party ownership agreements. After the CAS, Swiss courts and Belgian courts upheld the sanctions, the Belgian Court of Cassation referred the matter to the Court of Justice of the European Union.
The Court’s decision underscores that arbitration in sport — often imposed by governing bodies like FIFA — must operate in line with EU public policy, ensuring access to national courts to request remedies such as interim measures, damages, and the cessation of unlawful practices.
The case now returns to Belgium, where the Court of Cassation should remit it to the Court of Appeal, which will then reassess the compliance of the CAS award with EU law.
Find the full text of the judgment on CURIA.
For more information, please contact:
Bruno Lebrun – Partner – b.lebrun@jansonbe
Candice Lecharlier – Associate – c.lecharlier@janson.be
EU Adopts the 18th Sanctions Package Against Russia
EU Adopts the 18th Sanctions Package Against RussiaOn 18 July 2025, the EU adopted its 18th package of sanctions in response to Russia’s invasion of Ukraine. The new measures aim to intensify the economic pressure on Russia, target circumvention networks, and reinforce accountability efforts — particularly concerning violations of international law.
This new package focuses on five key areas: reducing Russia’s energy revenues (including a lowered oil price cap and bans on oil-derived products), tightening financial restrictions (with 22 additional banks listed), expanding export bans on critical technology and goods, and strengthening anti-circumvention tools with new listings in Russia, Türkiye, and China.
The EU has also sanctioned individuals and entities involved in the indoctrination and deportation of Ukrainian children, as well as Russian proxies and propagandists in occupied territories.
Belarus is additionally targeted, with new bans on arms procurement, banking transactions, and advanced tech exports.
With 55 new individual and entity listed, 105 more shadow fleet vessels, and a broadened scope of enforcement, this package significantly reinforces the EU’s restrictive measures architecture.
Finally, three tankers have been de-listed following firm commitments that they will no longer engage in the transport of Russian energy to the Russian Yamal and Arctic 2 projects for which they were initially commissioned.
Key regulations include Regulation (EU) 2025/1472, Regulation (EU) 2025/1494, Implementing regulation (EU) 2025/1469 and Implementing regulation (EU) 2025/1476.
For more information, please contact :
Bruno Lebrun – Partner – b.lebrun@janson.be
Cédric Alter – Partner – c.alter@janson.be
Dominique Blommaert and Céline Masschelein receive recognition for their top-tier expertise
Dominique Blommaert and Céline Masschelein receive recognition for their top-tier expertise
Don’t hesitate to read the full article here from Made in : West-Vlaamse advocaten Dominique Blommaert en Céline Masschelein (Janson) krijgen vanuit Londen erkenning omwille van hun vakwerk op Champions League-niveau - Made in