ABSTRACT
Embracing administrative cooperation as a powerful way to enter into contact with the UN sanctions bodies would have implications for the EU constitutional order as a whole. Activating the institutional capacities of the EU administration to really converse with the UN administration and seeing this as an inherent part of the administrative role points the way to a constitutional order which acknowledges and internalizes that sanctions operation and legitimacy is not a purely internal affair. The focus on administrative cooperation works against the paradigm of separation without completely leveling differences between legal orders rather; it addresses mutual dependencies and the necessity to act on them. However, the judgment has the potential to reorient the discourse on EU-UN relations in the realm of sanctions toward an understanding that requires direct, sustained engagement of all actors. The rhetorical footsteps of Maduro, the Court drew on the full arsenal of constitutional rhetoric in its 2008 Kadi decision.
