Tag Archives: export control

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

European Commission Published a Draft Guidance on the Internal Compliance Program

The European Commission published its draft guidance on the internal effective export control compliance programs. The guidance is subject to public consultation with all interested  stakeholders. In order to take part in the consultation, it is necessary to submit a contribution via the on-line survey.… 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

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 Export Control Organisation (ECO) Revokes Six Open General Export Licences (OGELs)

On 5 April 2017, the ECO revoked the following OGELs, including: Exports of military goods, software and technology (new OGEL for Military Goods, Software and Technology) Exports under the US-UK Defence Trade Co-operation treaty (new OGEL for Exports under the US-UK Defence Trade Cooperation Treaty) Exports of military goods, software or technology to a government … Continue Reading

Developments Regarding the Revision of the Dual-Use Export Control Regime

On 28 September 2016, the European Commission published its proposal to “modernise and strengthen” the EU’s dual-use export control regime as laid out by Regulation (EC) No. 428/2009. Now that the commissioner’s proposal has been published, it must be examined by the council and the European Parliament. All three must agree in order to adopt … Continue Reading

UK Export Control Organisation (ECO) Publishes New Guidance on Using SPIRE

On 9 January 2017, the ECO published new guidance on how to use SPIRE to get an export licence. The guidance sets out the various steps required for completion before exports can use SPIRE. These steps include registering and having available: the EORI number; the export control classification of the items in question; the supporting … Continue Reading

UK Export Control Organisation (ECO) Updates Sixteen Open Licences

The UK ECO has published a notice that it has updated and amended 16 open licences including 13 open general export licences (OGELs), two open general transshipment licences (OGTLs) and an open general trade control licence (OGTCL). The reason for the change is due to a planned update to the Military List to reflect the … Continue Reading

Developments Regarding the Revision of the Dual- Use Export Control Regime

On 28 September 2016, the European Commission published its proposal to “modernise and strengthen” the EU’s dual-use export control regime as laid out by Regulation (EC) No. 428/2009. Now that the commissioner’s proposal has been published, it must be examined by the council and the European Parliament. All three must agree in order to adopt … Continue Reading

UK Export Control Symposium 2017 – London, UK – 21 March 2017

The UK government’s Department of International Trade Export Control Organisation (ECO) will put on this year’s Export Control Symposium on Tuesday 21 March at the Westminster Conference Centre. The symposium will include plenary session covering wide ranging global trading issues, four specialist workshops, and networking “village” for delegates and exhibitors.… Continue Reading

DDTC Publishes Final Rule Revising USML Categories VIII and XIX

In the latest steps taken to implement the President’s Export Control Reform initiative, DDTC has published a final rule implementing revisions to Categories VIII (aircraft and related articles) and XIX (gas turbine engines and associated equipment) of the United States Munitions List (USML). Among other things, the rule clarifies the scope of items covered by those … Continue Reading

EU Commission Publishes Report on Dual-Use Export Control Regime

In its annual report to the European Parliament on the EU’s export control regime for dual-use goods, the EU Commission states that dual-use goods are estimated to represent 20% of all EU total exports, and that a large amount of dual-use exports outside of the EU are to E001 countries benefiting from general export authorizations and in particular the US. … Continue Reading

Civil Monetary Penalties for Sanctions and Export Control Violations Set to Increase

Under the authority of the Federal Civil Penalties Inflation Adjustment Act of 1990 (the Act), as amended, OFAC is adjusting for inflation the maximum amount of the civil monetary penalties that may be assessed under its relevant regulations. For instance, for penalties assessed under the authority of the International Emergency Economic Powers Act (IEEPA), penalties will increase to the greater … Continue Reading

UK Government Launches Export Control Joint Unit (ECJU)

As an integral part of the UK government’s 2015 Strategic Defence and Security Review, the Export Control Joint Unit began operating on 18 July. The ECJU brings together staff and resources from the Export Control organisation, the Foreign and Commonwealth Office and the Ministry of Defence to promote global security through strategic export controls and … Continue Reading

Export Control Organisation (ECO) Amends Two Open General Export Licences (OGELs)

The UK’s ECO has updated two of its OGELs: the Military Goods: Collaborative Project Typhoon licence and the International Non-Proliferation Regime Decontrols: Dual-Use Items licence. The former licence has been updated to add Kuwait to the list of authorised destinations for the export of military goods for the maintenance of Typhoon aircraft. The latter licence has been updated to remove … Continue Reading

Export Control Reform Continues Through Changes to Key Terms

In June, the US Commerce Department’s Bureau of Industry and Security (BIS) and the State Department’s Directorate of Defense Trade Controls (DDTC) published companion rules to harmonize the definitions of key terms in the Export Administration Regulations (EAR) and the ITAR, respectively. The terms affected by the rulemaking include such fundamental concepts in export controls as “export”, “reexport”, “release”, “transfer” … Continue Reading
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