Financial sanctions for Libya: an update on UN, EU and Dutch legislation
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On 3 March 2011, Clifford Chance published a client briefing "Sanctions affecting Libya" outlining the first regulations with sanction provisions relating to the current situation in Libya. Since then, on 17 March 2011, the United Nations Security Council adopted a new resolution, concerning the situation in Libya and authorising 'all necessary measures' to protect civilians and civilian populated areas.
Since then, the EU has also has amended the Council Regulation (EU) 204/2011, dated 2 March 2011. In addition to designating a further number of persons and entities to Annex II and III of the Council Regulation (EU) 204/2011, rules regarding the no-fly zone have been incorporated. Also additional exemptions have been added to this regulation, of which the most important one is the exemption for subsidiaries in which a designated entity has a stake.
The below briefing summarizes the two latest amendments to Council Regulation (EU) 204/2011.