The EU sanctions regime will remain formalistic unless liability for its violation extends to the entire chain of involved actors. Punishment must be inevitable and deterrent, and expanding liability to intermediaries and other links in sanctions evasion schemes should make the risk of violating sanctions too high.
This was stated in a comment to Guildhall by Lithuanian Seimas member Emanuelis Zingeris.
According to Emanuelis Zingeris, “the most important principle is that punishment must be inevitable and deterrent.” He stressed that “liability must extend to the entire chain of involved entities.”
As the MP noted, “if only the ultimate beneficiary is punished, the rest of the chain of intermediaries can continue to serve other beneficiaries,” and “in this way sanctions remain only ‘on paper.’”
At the same time, he said, “expanded liability encourages actors to invest in sanctions compliance,” because “the risk of violating or circumventing them becomes too high.”
German Member of the European Parliament Lukas Sieper stated that liability for circumventing sanctions against Russia should extend to all participants in the scheme — from intermediaries and financial institutions to logistics operators and entities in third countries — if they knowingly participated in, facilitated, concealed, or benefited from the violation of the sanctions regime.
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