16.1. Sources of Jurisdiction
extraterritoriality
vessel
At the outset of this Section it is worth noting that despite the heading being named 'Territorial' scope, this Section covers 'all' scopes of application of sanctions regulations. The territorial scope is only one of these 'scopes'. Other scopes are, for example, the personal scope of application, such as the application to EU nationals and legal entities incorporated in the Union. It is often argued in practice that sanctions do not apply extraterritorially. This is, in my view, technically correct, however, as will be shown in this Section, sanctions apply worldwide to EU nationals and EU legal entities without regard where the actions are taking place. Thus, what is meant when stating that EU sanctions do not apply extraterritorially is that sanctions do not to apply to actions between non-EU persons taking place outside of the Union in relation to non-EU assets.