Trade Practitioner

Subscribe to all posts by Trade Practitioner

Airbus Operations Limited: A record UK export control settlement

On 30 July 2026 HMRC announced its largest compound settlement on record for export control offences: £6,409,388, paid by Airbus Operations Limited to settle multiple breaches of the UK’s strategic export control regime. The published notice identifies no unlicensed export and no diversion – the sum answers for repeated failures to keep the records and … Continue Reading

The cancelled buy-back: Federal Law No. 319-FZ and the departing seller’s option: Compensation at the court’s discretion

On 4 August 2026, the President of the Russian Federation signed Federal Law No. 319-FZ, which inserts a new Article 20.1 into the Federal Law on Foreign Investments and allows a Russian court to cancel the buy-back option that many departing foreign investors took in place of a market price when they left Russia after … Continue Reading

Department of Defense suspends CMMC Phase II implementation and seeks industry input on future reforms

The Department of Defense (DoD) Chief Information Officer CIO suspended implementation of the Cybersecurity Maturity Model Certification (CMMC) Phase II on July 13, 2026  and launched a CMMC Review and Reform Task Force to reassess the CMMC program, reduce compliance burdens, and gather direct industry feedback regarding future cybersecurity requirements. Based on the recently issued … Continue Reading

The US extends EAR enhanced favourable treatment to the UAE: Country group reclassification and the advanced-computing carve-out

On 10 July 2026, the Bureau of Industry and Security issued a final rule removing the UAE from Country Groups D:3 and D:4 of the Export Administration Regulations and adding it to Country Group A:5, the group that receives the most favourable licence-exception treatment the EAR offers. The rule took effect on filing, 10 July … Continue Reading

Dueling lists: China’s answer to the Section 1260H expansion and the risk in the pattern – what US stakeholders should know

On June 22, 2026, the People’s Republic of China announced new restrictive measures affecting dozens of US companies, in a move coming just two weeks after the US Department of Defense’s June 8 expansion of its Section 1260H list of “Chinese Military Companies” list. These latest measures clear examples of Washington and Beijing increasingly reaching … Continue Reading

Court Affirms Crack Down on Foreign Ties in a Proposed US Government Grant Award

A US Small Business Innovation Research (SBIR) award denied due to security threat of co-owners’ foreign ties after national security review. On June 8, the US Court of Federal Claims (USCOFC) published its opinion affirming the Air Force’s denial of a SBIR award due to the applicant’s ties to a foreign country of concern.[1]… Continue Reading

The UK’s new consolidated Dual-Use Open General Export Licence

The UK’s Export Control Joint Unit announced on 25 June 2026 (in Notice to Exporters 2026/14) a new consolidated Dual-Use Open General Export Licence merging the existing EU member states Dual-Use OGEL and General Export Authorisation 001 into a single open licence and extending open-licence coverage to five new destinations. For the trade practitioner, the … Continue Reading

OFAC’s General License X and the easing of Iran energy sanctions

The US Treasury Department’s Office of Foreign Assets Control (OFAC) released General License X (GL X) on June 22, 2026, providing temporary easing of restrictions on Iran’s energy sector. These are the first substantive sanctions relief for Iran’s energy sector since 2016, when OFAC implemented the US-Iran Joint Comprehensive Plan of Action (JCPOA). We recently … Continue Reading

The UK’s 16 June 2026 Russia sanctions package and the OFSI interdiction general licence

On 16 June 2026, as the prime minister attended the G7, the UK announced 70 new sanctions under its Russia regime, comprising 43 designated persons and entities and 27 specified ships, directed at Russia’s shadow fleet, a Main Directorate of the General Staff of the Armed Forces of the Russian Federation (GRU)-linked procurement network centred … Continue Reading

The Council of the EU’s June 2026 restrictive measures against Russia

On 15 June 2026, the Council of the EU adopted a further set of restrictive measures in response to what it terms Russia’s war of aggression against Ukraine, adding 34 individuals and 47 entities to the EU’s asset-freeze and travel-ban lists across three sanctions regimes, and renewing the measures responding to the annexation of Crimea … Continue Reading

The “real risk” threshold for sanctions exposure: The Court of Appeal in The Catalan Sea

On 22 May 2026, the UK’s Court of Appeal handed down its judgment in Tonzip Maritime (Singapore) Pte Ltd v. 2 Rivers Pte Ltd (The Catalan Sea) [2026] EWCA Civ 641, allowing the shipowners’ appeal and confirming that a charterparty clause permitting refusal of a voyage order which would “expose” the owners to sanctions is … Continue Reading

AUKUS announces its first Pillar II signature project: Uncrewed undersea capabilities

On 30 May 2026, at the Shangri-La Dialogue in Singapore, the US, the UK and Australia announced the first signature project under Pillar II of the AUKUS partnership: the joint development of payloads and enabling systems for uncrewed undersea vehicles, with first capabilities expected in service from 2027. For the trade practitioner, the announcement’s significance … Continue Reading

Sanctions, National Security, and Countermeasures in Convergence: The European Operator Between Competing Obligations

Across April and May 2026 a sequence of regulatory developments redrew the operating environment for European companies engaging with Chinese counterparties. The State Council of the People’s Republic of China promulgated two consolidated countermeasures instruments: Order No. 834 of 31 March 2026 (the Supply Chain Provisions, 供应链产业链安全管理条例) and Decree No. 835 of 13 April 2026 … Continue Reading

The Dutch government blocks a US investor for national security reasons

In May, the Dutch government formally prohibited Kyndryl from its proposed acquisition of Solvinity, the Dutch IT services provider, following a recommendation by the Bureau Toetsing Investeringen (BTI). The prohibition was adopted under the Dutch telecommunications security screening regime rather than under the broader Dutch foreign direct investment (FDI) framework introduced by the Vifo Act.  … Continue Reading

BIS Issues One-Year Suspension of Affiliates Rule Expansion

On November 10, 2025, the US Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule titled “One Year Suspension of Expansion of End-User Controls for Affiliates of Certain Listed Entities.” As the title indicates, the final rule formally enacts a one-year suspension of the BIS Affiliates Rule, which had been in … Continue Reading

China Expands Export Control on Rare Earth Minerals and More

On October 9, 2025, China’s Ministry of Commerce (MOFCOM) announced two new decrees (the “New Rules”) significantly expanding and strengthening export controls over the rare earth supply chain: Decree No. 61 primarily targets foreign-made rare earth metals and products, while Decree No. 62 focuses on the control of rare earth-related technology.… Continue Reading

Russia Adopts Fast Track Mechanism for Selling Federal Assets

On September 30, 2025, President Vladimir Putin signed Decree No. 693 “On Certain Particularities of the Sale of Property in Federal Ownership”. The measure took effect the moment it was published. The decree is expressly framed as a response to “unfriendly” actions by the United States and its allies. It is adopted “to protect the … Continue Reading

A Discussion on 232 Tariff Revisions

Squire Patton Boggs representatives have recently led several discussions with US Customs and Border Protection (CBP) over the current evolution of Section 232 regulations on aluminum and steel. Based on these conversations and our own evaluation of the landscape, we provide the following summation of the 232 regulatory revisions released on June 3, 2025 and … Continue Reading

EU Lifts Key Sanctions on Syria: Legal and Compliance Implications Amid Evolving Opportunities

Earlier this week, the Council of the EU adopted a series of legal instruments giving effect to what had been agreed on 20 May 2025, to significantly reduce sanctions on the Syrian Arab Republic. As a result, all EU economic restrictive measures targeting Syria have been lifted, except for those maintained on specific security-related grounds. … Continue Reading

EU Adopts 17th Sanctions Package Against the Russian Federation: Further Targets the “Shadow Fleet” and Expands Export Controls

On 20 May 2025, the European Council announced its 17th sanctions package against the Russian Federation. The latest measures reinforce the EU’s strategic objective of undermining Russia’s capacity to finance and sustain its war efforts in Ukraine.… Continue Reading

European Commission Previews New Round of Countermeasures Against the United States

In April 2025, the European Union (“EU”) set tariffs on a series of US imports but immediately suspended their application until 14 July 2025. This was due to the US almost simultaneously announcing that it would be softening its across-the-board tariffs. In the case of EU exports, this meant going from a 20% to a … Continue Reading

Committee on Foreign Investment in the US (CFIUS) “Fast-Track” Pilot Program Being Developed

On May 8, 2025, the US Department of the Treasury (Treasury) announced that it “will establish a fast-track process” to facilitate the review by CFIUS of foreign investment into the US from “allies and partners sources . . . where there is verifiable distance and independence from foreign adversaries or threat actors.” The announcement noted … Continue Reading
LexBlog