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EU Publishes New Best Practices Guidance, including Updated Ownership Test and Additional Control Guidance

Key Takeaways - On 3 July 2024, the Council of the European Union (the “EU Council”) published its revised Update of the EU Best Practices for the effective implementation of restrictive measures (“Best Practices”).This...more

Updates to the UK National Security and Investment Act

Key Points - Following our Alert last month addressing the United Kingdom Government’s intentions to improve the workings of the National Security and Investment Act 2021 (NSIA), the U.K. Government has now published two new...more

Updates to the UK National Security and Investment Act in These Dangerous and Uncertain Times

Key Points - On Thursday, the UK government announced its intention to improve the workings of the NSIA, “ in these dangerous and uncertain times [when] our economy is increasingly the target for our adversaries.” In November...more

International Unilateral Export Controls—An Increased Focus on Advanced Technologies

On 11 March 2024, the UK expanded its export control regime to include new controls on specific emerging technologies, such as quantum computing, semiconductor technologies and additive manufacturing, under The Export Control...more

New EU & UK Sanctions

EU’s 12th Sanctions Package - On 19 December 2023, the Council of the European Union (EU) together with the Commission published its 12th round of sanctions....more

Following EU, UK to Levy a Carbon Border Adjustment Mechanism

The UK announced that it will require importers to pay a carbon levy on certain goods imported from countries with a lower or no carbon price. Covered goods under the UK’s carbon border adjustment mechanism (CBAM) likely...more

Bank Otkritie v Mints Case and Ownership and Control

Key Takeaways - On 17 November 2023, the Foreign, Commonwealth & Development Office (FCDO) and Office of Financial Sanctions Implementation (OFSI) published new guidance on Ownership and Control: Public Officials and...more

Financial Restrictions on Russia Increase with Additional Focus on Sanctions Circumvention

On 23 June 2023, the European Union (EU) adopted a new package of economic sanctions against Russia. In addition to other measures, the 11th sanctions package has specifically widened prior financial restrictions applicable...more

2022 Economic Sanctions Year in Review and Outlook for 2023

Introduction - In 2022, the United States, European Union (EU) and United Kingdom, along with a significant number of other partners and allies, imposed an unprecedented number of economic, financial and trade sanctions...more

UK Extends the Authority to Designate Persons and Entities Under Its Sanctions Against Russia

The United Kingdom just issued a new statutory instrument, effective immediately, which extends the authority to designate persons and entities under the U.K. sanctions against Russia. Previously, the U.K. government...more

Ukraine-Russia Crisis: Possible New Sanctions and Export Controls on Russia and Potential Implications for U.S. and Non-U.S....

Key Points - The United States, European Union, United Kingdom and other U.S. allies are currently considering a range of severe economic measures against Russia to impose in the event of a Russian military incursion into...more

Extraterritorial U.S. Sanctions and EU Blocking Rules: Damned If You Do, Damned If You Don’t

Court of Justice of the European Union sets Binding Rules on the Contractual Impact of the EU Blocking Regulation The EU Blocking Regulation (the “Regulation”)1 prohibits compliance by EU persons with certain U.S....more

UK Government Consultation on Proposed Power to Block Listings on National Security Grounds

Key Points - The proposed power would allow the UK Government to block initial equity listings and admissions on UK public markets on the grounds of national security. The listing of debt securities (other than...more

The Recast Dual Use Regulation – A Missed Opportunity

Key Points - On 11 June 2021 the European Union (the “EU”) published Regulation (EU) 2021/821 (the “Recast Regulation”) in its Official Journal, which marked the final step with respect to modernizing its existing dual use...more

Protecting the Crown Jewels: U.K. National Security & Investment Act to be Enacted in Autumn

While the U.K. has a mature approach to protecting national security overall, the government lacks effective statutory powers in relation to the ownership and control of businesses and other entities that could be used to...more

EU-UK Trade and Cooperation Agreement: Initial Impact on Trade Topics

The U.K. and the EU conclude the EU-UK Trade and Cooperation Agreement, which entered into force on December 31, 2020. The Agreement provides guidance on origin rules that must be met for products to benefit from duty-free...more

Turkey: U.S. and EU Sanctions Developments

Key Points - On December 14, 2020, in response to Turkey’s procurement of the S-400 surface-to-air missile system from Russia in 2019, the Trump administration imposed new sanctions on the Turkish Presidency of Defense...more

Protecting the Crown Jewels: U.K. Introduces Expansive National Security & Investment Bill

1. Summary The United Kingdom (U.K.) government published the National Security and Investment Bill (“NSI Bill” or “Bill”) on November 11, 2020, the aim of which is to strengthen the government’s powers to scrutinize and...more

Updated 5G National Security Report Issued by European Commission

- On July 24, the European Commission (EC) published an updated report (the “Report”) on the progress made by member states in implementing measures aimed at addressing the national security risks and mitigation strategies...more

Human Rights Due Diligence: Increasing Regulatory Pressure for Clean Supply Chains

- There is increasing regulatory, commercial and media attention in the U.K. and the EU regarding the role of human rights in company supply chains. - The U.K. and the EU are introducing specific measures around human...more

U.K. Announces “Magnitsky Act-style” Global Human Rights Sanctions and 49 Designations

- As of 1:00 p.m. BST July 6, 2020, the GHR Regulation came into force, representing the introduction of the U.K.’s long awaited GHR Regime. - The GHR Regime is the first standalone U.K. sanctions regime to be in current...more

Attempted Imagination Coup Triggers UK Push for More National Security Blocking Powers on Foreign Asset Stripping

- On April 21, 2020, Imagination Technologies, a U.K. based company producing graphics processing units used in 11 billion devices globally, was summoned to answer questions by MPs in relation to national security concerns....more

10 Things You Need to Know About the EU White Paper on Artificial Intelligence

On February 19, 2020, the European Commission (Commission) published proposals for the regulation of Artificial Intelligence (AI) with potentially far-reaching implications both for users and developers worldwide. The...more

International Trade Impacts of The Coronavirus: Update On Government And Industry Actions And Key Considerations For Trade...

The new coronavirus, SARS-CoV-2, and the disease it causes, COVID-19, have created diverse, complex, and immediate challenges for world governments, multinational businesses, and other international institutions and projects....more

EU Trade Update: Council Issues Negotiating Mandate for Recast Dual Use Regulation

• On June 5, 2019, the European Union (EU) took a step forward with respect to modernizing its existing dual use legislation under Council Regulation (EC) No 428/2009 (the “EU Dual Use Regulation”), with the European Council...more

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