family member
firewall
This Section addresses in detail the asset freezing measures. It covers the time element of the asset freeze, i.e. the beginning and the end of the freeze. Further, it addresses freezing actions, i.e. actions taken by operators in relation to frozen assets, such as account blocking or the seizure of assets. Later, this Section deals with the extent of freezing measures, both in terms of the substantive and the territorial extent. Furthermore, this Section addresses the highly relevant issue of ownership and control of sanctioned persons in relation to legal entities and the extension of the asset freezing measures to such non-sanctioned legal entities. Finally, this section concludes with some specific scenarios, such as asset transfers to close family members, funds of non-sanctioned persons transferred from sanctioned banks and the instrument of the ‘firewall’.