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Most commonly, sanctions and other restrictive measures apply only to persons and entities within the jurisdiction of the issuing country. However, the so-called United States (“U.S.”) “secondary” sanctions have a much wider scope of application in that they have a significant constraining effect on all persons and entities regardless of the location, place of incorporation or national identity. In the EU, measures having such an effect are referred to as extra-territorial measures.
1 The impact of extra-territorial measures on the EU economy has not been insignificant: Since 2018, Airbus lost an estimated €17 billion, having to walk away from a contract with Iran Air, Daimler was forced to terminate its joint venture with an Iranian car manufacturer, French car manufacturers PSA and Renault lost approximately €850 million due to a cancelled deal, and Total had to abandon a €4.25 billion development in the I
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