Non-Paper No 01/2026: Firewalls under EU Sanctions Law: Lessons from the EuroChem Case

Written by Martin Seyfarth, senior partner for regulatory and government affairs at the international law firm WilmerHale, based in Berlin and Brussels. 

This Non-Paper analyses the legal framework governing the extension of asset freezes through ownership and control under EU sanctions law and examines the conditions under which operator-initiated firewalls may prevent the automatic extension of asset freezes. It considers the UK High Court’s recent judgment in the EuroChem case as a blueprint for how to structure, document and validate effective firewall arrangements, and the role of national competent authorities in assessing and recognising such arrangements. The paper concludes that properly designed and independently validated firewalls serve the dual function of upholding the integrity of EU restrictive measures while safeguarding legitimate businesses operations, particularly in critical sectors.