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EU Clears Up Regulation Language on Frozen Funds of Deceased Individuals Under Tunisia Sanctions Regime

For individuals criminally convicted for the misappropriation of European Union state funds, frozen funds belonging to those individuals relating to the EU's Tunisian sanctions regime can remain frozen after that person has died "until court orders for the recovery of…

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the misappropriated State funds and the payment of fines have been executed," the European Council said in a Feb. 3 regulation. If the deceased individual had not been criminally convicted, then the funds will remain frozen "for a reasonable period of time," the council said. If an action to recover misappropriated funds is brought during that period, the funds will remain frozen until "such action is dismissed or, if it is upheld, until the court’s order for the recovery of the misappropriated funds has been executed."