On Monday, 21 September, the EU designated three companies involved in the transportation of goods for violating the UN arms embargo in place for Libya: Sigma Airlines, Avrasya Shipping and Med Wave Shipping. The three entities, who are alleged to have transported military material to Libya, are now subject to an asset freeze under the EU restrictive measures.

Tensions over non-compliance with the UN arms embargo have escalated over recent weeks following the interim UN envoy for Libya, Stephanie Williams, criticising the “blatant” ongoing violations. In the press release which followed the designations, the EU reiterated its commitment to ensuring that the UN arms embargo in Libya is fully respected and stated that these “new listings show the EU’s strategic use of its sanctions regime and ability to react to developments on the ground in support of the political process and to deter past and present perpetrators from further violations”.

Those involved in Libya trade should continue to monitor developments, as further restrictive measures may follow. In the meantime, effective sanctions specific due diligence and compliance policies remain key to ensuring compliance, particularly in light of the guidance issued earlier this year by the sanctions enforcement bodies in the U.S. and the UK: OFAC client alert and the OFSI client alert.

If you have any queries, please contact a member of the Reed Smith sanctions team.