Resisting (US) Sanctions: A Comparison of Special Purpose Vehicles, Blocking Statutes and Countermeasures

Nathanael Tilahun

Research output: Contribution to journalArticlepeer-review

1 Citation (Scopus)
143 Downloads (Pure)


Trade-restricting unilateral sanctions could face resistance from the targeted states and other states and regional organizations whose trade or non-trade interests are affected by the sanctions. This is particularly true in response to sanctions by the United States, which imposes secondary sanctions affecting actors from a broad range of third states. States resist such sanctions through judicial and non-judicial methods. This paper looks at three non-judicial methods states increasingly take in response to sanctions – special purpose vehicles, blocking statutes, and countermeasures – and provides an analysis of the international law issues pertaining to each method. Based on this analysis, the paper offers a comparative assessment of the potential usefulness and legal limitations of these methods in resisting undesirable foreign sanctions.
Original languageEnglish
Pages (from-to)380-388
Number of pages9
JournalGlobal Trade and Customs Journal
Issue number9
Publication statusPublished - Sept 2022

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  • US sanctions
  • international law
  • special purpose vehicles
  • blocking statutes
  • countemeasures


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