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Anjum Shabbir
Anjum Shabbir
7th June 2021
External Relations & Trade

Analysis: “Advocate General Rantos in Council v Hamas: Council’s lack of signature of the statement of reasons for restrictive measures is not a valid ground for annulment” by Celia Challet

Advocate General (AG) Rantos delivered his Opinion in appeal case Council v Hamas (C-833/19 P) on 3 June 2021 concerning the validity of the counter-terrorism restrictive measures imposed against Hamas. What started as a classic action for annulment against EU restrictive measures has become a case of particular importance for the procedural rules applicable to these sanctions.

The key aspect of the case revolves around the following facts: in 2018, the Council of the EU adopted CFSP Decisions and TFEU Regulations that maintained the listing of Hamas. They were published in the Official Journal of the EU. The Council also notified these acts and their statements of reasons to Hamas. As often occurs in the field of restrictive meas


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