Blocking Regulation

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The Blocking Regulation is a 1996 European Union (EU) Regulation which prohibits EU companies from complying with certain extraterritorial US sanctions.

Managing conflicting rules

"The US's reimposition of sanctions against Iran prompted the European Commission to expand the scope of the 1996 EU Blocking Regulation.
The revised Blocking Regulation... in essence prohibits EU companies from complying with the reimposed US sanctions against Iran.

The Blocking Regulation is often described as putting those within its scope (EU companies, nationals and others within the EU) between a rock and a hard place.
Non-compliance may give rise to civil and, potentially, criminal penalties.
However, the penalties for a non-US person failing to comply with the US's secondary sanctions can include being cut off from the US financial system - and being unable to deal with US persons."
The Treasurer, October 2018, p43 - Slaughter and May.

See also