On September 18, 2014, the General Court of the Court of Justice of the European Union (the Court) rejected claims for damages [3] brought by Mr. Aguy Clement Georgias regarding his detention at Heathrow Airport due to restrictive measures [4] (freezing of funds and prohibition of entry into or transit through the territory of the European Union) that the Council of the European Union had imposed against him as a member of the Zimbabwe Government.  According to the press release [5], the Court held that any damage relating to Mr. Georgias detention at Heathrow “arose directly from a decision of the British authorities taken in the exercise of their sovereign powers (namely, powers relating to controlling the entry of citizens of non-member countries to British territory).”  The Court further held that “the imposition and maintenance of the restrictive measures against Mr Georgias by the Council were valid.  Therefore, one of the conditions necessary for the EU to incur liability, namely, unlawful conduct on the part of the institution concerned, is not satisfied.”