SANCTIONS CLAUSE

The sanction clause refers to a reminder of the obligation of recipients of EU funds established in the EU to comply with sanction regimes. EU sanctions comprise both economic and non-economic sanctions. The EU Council imposes restrictive measures within the framework of the CFSP. The Council first adopts a CFSP Decision under Article 29 of the TEU. Measures such as arms embargoes or travel restrictions are implemented directly by member states, which must act in conformity with CFSP Council Decisions. Other measures, such as freezing funds, are implemented by way of Regulation, adopted by the Council, on a joint proposal from the Commission and the High Representative of the Union for Foreign Affairs and Security Policy under Article 215 of the TFEU.

The sanction clause refers to the obligations to comply with sanction regimes but also recalls the humanitarian principles, in particular the principle of impartiality. It clarifies further that final beneficiaries will not have to be vetted. This provision will apply irrespective of the type of exceptions (derogations or exemptions) included in individual sanction regimes.

The sanction clause is generic and covers all sanction regimes (including counter terrorism).

No, the exception to the requirement of vetting/screening applies only to people in need/final beneficiaries.

Vetting and screening means the same, i.e. checking whether the person is listed in the sanctions regime.