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See the notice on 'Method of citing the case-law of the Court of Justice of the European Union on the basis of the ECLI (European Case-Law Identifier)' on the CJEU's website (http://curia.europa.eu). 51 E.g. (European Court of Human Rights, Case of M.S.S. v. Belgium and Greece, Application No. 30696/09, 21 January 2011.). See the Court's Note explaining the mode of citation and how to refer to the judgments and decisions of the Court (old and new) (October 2013). 52 For the UK, citations refer to the law report the case was published in, e.g. Maronier v. Larmer, [2002] EWCA Civ 774. For France and other Member States, citations include the court that delivered the judgment, the date, and the case number, e.g.

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In this article the question is asked whether asset freezing can be qualified as a criminal charge within the meaning of Article 6 ECHR and if yes, what effects this qualification may have on the legislative framework on so called smart sanctions. By analysing Community and EU law and case law of the European Court of Human Rights, General Court of Instance and Court of Justice of the European Communities the authors give an overview of the notion and possible qualification of asset freezing as a criminal charge. The article further focusses on the consequenses of qualifying asset freezing as a criminal charge under ECHR and EC/EU law and concludes by answering the aforementioned question.

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