Archives: Europe & Central Asia

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US-EU Export Controls and Sanctions Alert: In Case of Hard Brexit, EU and UK Issue Plans for Export of Dual-use Goods

Due to the vacillating political developments in the UK, a “hard Brexit” scenario (meaning, no withdrawal agreement reached between the EU and UK by the withdrawal date of March 30, 2019) is likely to happen. In preparation for a no-deal withdrawal, which would affect the trade of dual-use items between the EU and the UK, the European Commission (the Commission) … Continue Reading

EU Adopts CFIUS-like Framework for Sake of National Security

EU goes ahead with a European framework, similar in intents and purposes as the Committee for Foreign Investments in the United States (CFIUS), for screening incoming foreign direct investments… extra scrutiny over foreign investments that might affect public order and security. On December 10, 2018, the European Parliament Committee on International Trade (INTA) approved the EU Regulation establishing a framework for screening of … Continue Reading

UK Provides Guidance on Exporting Controlled Goods if There is No Brexit Deal

The Department for International Trade has produced guidance, published on August 23, 2018, informing stakeholders how export controls would be affected if the UK leaves the EU with no deal. The notice explains how export licensing requirements for different groups of items would change and what the UK government proposed to simplify licensing. The export of many controlled items within … Continue Reading

ECJU Amends Export Control Order 2008 and Publishes Firearms Export Guidance

The export control joint unit (ECJU) has amended the Export Control Order 2008 with effect from September 14, 2018. The new Order extends the controls on firearms to include devices capable of being converted to firearms. The ECJU has also updated the consolidated control list of strategic military and dual-use items that require export authorization. The additional devices include the … Continue Reading

OFSI Updates Financial Sanctions

The Office of Financial Sanctions Implementation (OFSI), which is part of HM Treasury and works to ensure that financial sanctions are properly implemented and enforced in the UK, has  updated a number of financial sanctions currently in force. The recent updates are as follows: Financial sanctions, Libya; Financial sanctions, Ukraine (Sovereignty and Territorial Integrity); Financial sanctions, North Korea (Democratic People’s … Continue Reading

2018 UK Government Export Control Symposium

George Grammas, Co-Chair of our International Trade/Global Import and Export Compliance Practice, will present on US export controls topics at the upcoming Manchester Export Symposium hosted by the UK Government Department for International Trade on November 6 in Manchester, UK. The symposium will include plenary session and workshops, and provide attendees with networking opportunity with … Continue Reading

UK Company Fined Six-figure Sum for Illegal Exports

An unnamed UK company has recently been fined £109,312.50 for making unlicensed exports of military goods controlled by the Export Control Order 2008. The fine was issued by Her Majesty’s Revenue and Customs (HMRC), which is responsible for enforcing UK export control legislation in collaboration with the Crown Prosecution Service. The fine is an example of HMRC using its powers … Continue Reading

UK Issues Guidance on Application of the “Cryptography Note”

The UK has issued guidance to assist exporters to make their own assessment on the application of the “Cryptography Note” – Note 3 to Category 5 Part 2, Information Security as it appears in Annex I to Council Regulation (EC) No. 428/2009 (as last amended by Regulation (EU) No. 2268/2017). Products that use cryptography are usually controlled under the … Continue Reading

UK Amends the Consolidated List of Strategic Military and Dual-use Items

On 5 March 2018, the Export Council Joint Unit (ECJU) of the UK Department for International Trade updated the Consolidated Control List of Strategic Military and Dual-use Items that Require Export Authorisation. The updated list notably takes into account changes made to Schedule 2 of the Export Control Order 2008, which lists the military goods, software and technology subject to … Continue Reading

Brexit: Developments in Parliament on UK Trade and Sanctions Bills

The UK Trade Bill continued to be debated in the House of Commons with a second reading taking place on 9 January 2018. One of the main contributions of the bill is the establishment of the UK Trade Remedies Authority, an institution responsible for investigations into trade remedies, a responsibility currently assigned to the European … Continue Reading

UK Implements EU’s Venezuela Sanctions Regime

On 6 December 2017, the Venezuela (European Union Financial Sanctions) Regulations 2017 entered into force in the UK. This regulation implements Council Regulation (EU) 2017/2063 of 13 November 2017 and provides for the imposition of restrictive measures on persons or entities considered to be involved in undermining democratic principles and the rule of law, as … Continue Reading

UK Issues Guidance on Form to Release Information on Classified Goods and Services to Foreign Nations

On 29 January 2018, the ECJU published a guidance on the MOD Form 680 allowing firms to apply for permission to release information about classified goods and services to foreign nations. According to this guidance, the outcome of a MOD Form 680 request depends on various factors, including the complexity of the project, protective opportunities … Continue Reading

UK Amends the Consolidated List of Strategic Military and Dual-Use Items

On 17 January 2018, the UK’s ECJU of the UK Department of International Trade updated the Consolidated Control List of Strategic Military and Dual-use Items that Require Export Authorisation. The updated list notably takes into account the changes made to the EU dual-use export control list (See Annex I of the above link).… Continue Reading

UK Revokes Certain Open General Export Licences

On 4 January 2018, the Export Council Joint Unit (ECJU) of the UK Department for International Trade revoked Open General Export Licences (OGELs) applicable to dual-use technology items, cryptographic development, low value shipments, and dual-use items for oil and gas exploration, as well as OGELs for Turkey. The ECJU suggested they will be replaced very … Continue Reading
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