Delisting in the EU and the United Kingdom: Procedures, Time Limits and Evidence
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This report compares the procedures for challenging individual sanctions listings in the European Union and the United Kingdom. It examines administrative reconsideration, judicial review, procedural time limits and the evidence needed to address the applicable designation criteria. Selected litigation, including Aven and Fridman, Timchenko and Shvidler, illustrates the treatment of business interests, association, changes of circumstances and proportionality. The analysis distinguishes annulment of a particular act, removal from a sanctions list, non-renewal, licensing and correction of mistaken identity. It explains why success concerning one measure or period does not necessarily end all restrictions, particularly where renewed listings or parallel sanctions in other jurisdictions remain relevant. The report also considers implementation, interim protection and the restoration of services, linking the relief sought to the precise legal basis, contested decision, evidential record and continuing practical consequences.



