Under the second Union restrictive measures, operators are
prohibited from making funds or economic resources available (directly or indirectly) to sanctioned persons (Art. 2(2)). The legal form of the transfer is irrelevant (such as gift, sale or barter). “
It encompasses all the acts necessary under the applicable national law if a person is effectively to obtain full power of disposal in relation to the economic resource concerned. The prohibition on making economic resources available applies to any mode of making available an economic resource, whatever the consideration. The fact that economic resources are made available against payment of a consideration which may be regarded as adequate is therefore irrelevant." (emphasis added)
