EU revokes sanctions regime in Egypt

On 12 March 2021, the Council of the EU revoked the bloc’s framework for sanctions against persons identified as responsible for the misappropriation of Egyptian state funds and lifted the restrictive measures currently in force against nine Egyptian individuals.

Restrictive measures were initially adopted in 2011 following the Arab Spring under Regulation (EU) No 270/2011 (most recently updated in March 2020, which can be found here) and was aimed at assisting the Egyptian authorities with the recovery of misappropriated state assets. The measures consisted of an asset freeze imposed on listed individuals. In addition, nationals from EU member states and legal entities incorporated in the EU were prohibited from making funds available to those listed, either directly or indirectly. Since 2011, the Egyptian sanctions regime has been reviewed on an annual basis with some individuals having been delisted over time.

Following the most recent review of the nine listings still in force, the Council concluded that the Egyptian sanctions regime has served its purpose.

The press release from the Council can be found here.

In relation to the UK Overseas Territories (including, Anguilla, Bermuda, the British Virgin Islands and the Cayman Islands) the sanctions regime introduced in 2011 (Egypt (Restrictive Measures) (Overseas Territories) Order 2011) broadly reflected the EU position. However, following Brexit, this has been updated to comply with changes to the UK sanctions regime, most relevantly under the Misappropriation (Sanctions) (EU Exit) Regulations 2020. A link to the 2020 Regulations can be foundhere.