For Cedric Ryngaert, there are limits to the duty to freeze assets of persons listed under the EU sanctions regime against Russia. In particular, he approves of a recent decision of the District Court of Amsterdam, which held that a listed shareholder in a Dutch corporation should not be barred from voting regarding matters of corporate governance. He argues that such voting need not result in funds being transferred to Russia, which could be used to fund the war in Ukraine. Still, he believes that the Court of Justice of the EU may want to give more guidance on the matter on the basis of a preliminary ruling.

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