歐盟發布了指南,旨在幫助企業識別公司、信託或法人等實體何時由受制裁者擁有或控制。指南警告稱,如果無辜者未能及時發現這種情況,他們可能會因違反制裁而被追究法律責任,並提出了一些檢測名單上人員參與的策略。
EU: New guidance on ownership and control of business entities
The European Union has published guidance to assist businesses identify when an entity such as a company, trust or legal person is owned or controlled by someone subject to sanctions. It warns that innocent persons risk being held legally responsible for breaching sanctions if they fail to spot when this is occurring and suggests some strategies for detecting the involvement of listed persons.
Sources
EU Sanctions Compliance Helpdesk
EU (sanctions due-diligence)