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This article first appeared on European Sanctions Law & Practice (http://europeansanctions.com/), a blog by Maya Lester (+44 20 7379 3550, maya.lester@brickcourt.co.uk), a barrister at Brick Court Chambers, and Michael O'Kane (+44 (0) 20 7822 7777 mokane@petersandpeters.com), head of Business Crime at Peters & Peters.