On 11 November 2019 the EU Council agreed to put in place a framework for sanctions (Council Regulation 2019/1890) against natural and legal persons involved in offshore drilling activities in the Eastern Mediterranean within Cypriot territorial waters. This follows from a longstanding dispute between EU and Turkey regarding those activities, which EU call illegal. No person has yet been placed on the sanction list but the EU Council is expected to do so in due course.

The Regulation (Article 2) provides that sanctions will be imposed against persons

1. being responsible for or involved in, including by planning, preparing, participating in, directing, or assisting, drilling activities in relation to hydrocarbon exploration and production, or hydrocarbon extraction resulting from such activities, which have not been authorised by the Republic of Cyprus, within its territorial sea or in its exclusive economic zone or on its continental shelf, including in cases where the exclusive economic zone or continental shelf has not been delimited in accordance with international law with a State having an opposite coast, activities which may jeopardise or hamper the reaching of a delimitation agreement;
2. providing financial, technical or material support for drilling activities in relation to hydrocarbon exploration and production, or hydrocarbon extraction resulting from such activities, referred to in point (a);
3. being associated with the natural or legal persons, entities or bodies referred to in points (a) and (b).

Once persons are listed, this will potentially impact on businesses which trade with Turkey’s offshore, drilling and energy sectors, as well as their banks, insurers and other related businesses.

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