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John Smith and Chloe Cina on the Sanctions Enforcement Landscape

Sanctions Space

CHAPTER

Analysis of Extended Investigation Times, Retrospectivity, Reporting Requirements, and Secondary Sanctions

This chapter delves into the challenges posed by prolonged investigation times on resource allocation, particularly in the banking sector. It also discusses the potential pitfalls of applying retrospectivity on statute of limitations, along with new reporting requirements in the EU to enhance sanctions implementation and the introduction of secondary sanctions in a framework targeting support for Russia's military sector.

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