EU SANCTIONS MAY APPLY TO ALL TCSPs WORLDWIDE
EU TCSP sanctions are widely drawn and have the potential to affect all TCSPs worldwide, not just those who are located within the EU.
This is because the sanctions apply to any EU person, including an EU national working for a non-EU TCSP or a non-EU TCSP conducting business wholly or in part within the EU.
If you have the required EU nexus, then you must comply with the sanctions, meaning that you cannot administer any structure or entity or provide fiduciary services to it, if it is caught by the rules.
Like all sanctions, the Regulation is broadly drafted and the recent amendments to it were made in a short time period, therefore interpreting its scope is complex.
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