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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

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

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

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

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

The EU Suspends Certain Sanctions on Syria to Support Economic Stabilisation, Political Transition and Reconstruction

To help the Syrian people achieve a peaceful and inclusive political transition, to aid the swift economic recovery and reconstruction of the country and to facilitate its eventual reincorporation into the global financial system, the EU has suspended with immediate effect a number of sanctions and restrictive measures that had targeted key sectors of the … Continue Reading

EU Publishes Regulation Banning Products Made With Forced Labour

On 12 December 2024, the Forced Labour Regulation (FLR) was published prohibiting products made with forced labour on the EU market. This is the definitive and legally binding version of the FLR.  As detailed in an earlier client insight, the prohibition on products made with forced labour, as set out in the FLR, and the resulting obligations and associated checks and enforcement, will only enter … Continue Reading

Key Updates on the Enhanced Due Diligence and Circumvention Requirements Under Council Regulation 833/2014

On 11 December 2024, the European Commission issued important updates to its Consolidated FAQs on the implementation of Council Regulation No 833/2014 and Council Regulation No 269/2014 (FAQs). These updates cover multiple topics, including due diligence requirements, circumvention and the introduction of a new chapter dedicated specifically to enhanced due diligence for operators involved in … Continue Reading

The stony road to de-fragmentation of EU Foreign Direct Investment Control (FDI)

On 9 September, Mario Draghi published a report on ‘The Future of European Competitiveness’ highlighting the need for the EU to strengthen its Investment Screening Mechanism. The report was part of a broader effort to assess and strengthen the EU’s economic and strategic resilience in response to rising global competition and geopolitical challenges. Draghi’s report … Continue Reading

G7 Issues New Recommendations to Prevent Circumvention of Sanctions Against Russia

The primary objective of this guidance is to ensure industry compliance with export controls and help businesses identify risks associated with circumvention of export restrictions directed against the Russian military-industrial complex. The joint guidance identifies the following priority areas: (i)products posing an increased risk of reexport to Russia; (ii) red flag indicators of potential export … Continue Reading

Decarbonizing the Global Shipping Industry: Is Hydrogen Fuel the Answer?

Decarbonization is coming to the global shipping industry. Accounting for nearly one- quarter of all carbon emissions from the world’s transportation sector and one billion tons of carbon dioxide annually, shipping stands at a critical juncture in its efforts to reduce carbon emissions and mitigate its environmental impact. Among the emerging alternatives to traditional fossil … Continue Reading

EU’s First M&A Investigation: A Step Forward in Foreign Subsidies Oversight

The European Union is intensifying its scrutiny of foreign investments under the 2023 Foreign Subsidies Regulation (FSR). As the latest development, the European Commission has announced this week that it has opened an investigation into a proposed acquisition by e&, the UAE state-owned telecom operator, of the assets of the Czech telecom company PPF Telecom. … Continue Reading

European Commission Investigates Chinese State-backed Company’s Participation in a European Tender Using New Powers Under the Foreign Subsidies Regulation

The European Commission has launched its first ever formal investigation into a potentially market-distorting foreign subsidy, exercising its powers under the 2023 Foreign Subsidies Regulation (FSR). The investigation concerns the participation of a Chinese state-owned train manufacturer in a public tender organized by the Bulgarian Ministry of Transport and Communications. The outcome of this case … Continue Reading

Unveiling the New EU Foreign Investment Regime

To address growing geopolitical tensions and technological shifts, the European Commission presented, on 24 January 2024, five new initiatives for strengthening the EU’s economic security. Part of the package is a proposal for a new regulation on the screening of foreign investments, whose aim is to update Regulation 2019/452 (FDI Regulation), which is currently in … Continue Reading

Another Domino Falls: UK to Follow the EU in Ending the Antitrust Exemption for Liner Shipping

In our blog back in October, we noted the European Commission’s decision to let the Consortia Block Exemption Regulation (CBER) as to liner shipping expire on 25 April 2024. In a subsequent client alert, we noted that we were also waiting to see what the US Congress and the Federal Maritime Commission (FMC) would do … Continue Reading

Interpretation of “Control” in UK-Russia Sanctions: Mints v PJSC National Bank Trust

Summary and Comment The Court of Appeal’s judgment in the Mints v PJSC National Bank Trust case clarifies some key aspects of the legal interpretation of the sanctions the UK has applied to Russia – the Russia (Sanctions) (EU Exit) Regulations 2019 (Regulations). In essence, the Court of Appeal has done three things:… Continue Reading

No More ‘Safe Harbor’ – European Commission to End the Antitrust Exemption for Liner Shipping

The European Commission has decided to end a rule exempting liner shipping services from certain EU antitrust rules, by letting the Consortia Block Exemption Regulation (CBER) expire on April 25, 2024. The decision came after the European Commission concluded that the CBER “is no longer fit for purpose.”… Continue Reading

The Xella Judgment: EU Court Limits Member States’ Discretion in Applying FDI Control Laws

On 13 July 2023, the European Court of Justice (ECJ/Court) issued an important judgment with relevance for the foreign direct investment (FDI) screening practice across the EU (Case C-106/22). In summary, the Court found that the national legislation prohibiting the acquisition of a strategic company by undertakings organised in accordance with the laws of a … Continue Reading
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