On 30 December 2020, the EU and China agreed in principle on a Comprehensive Agreement on Investment ("CAI"). The text of the agreement is not yet available,1 but the European Commission called it "the most ambitious...more
In this alert, we focus on the key takeaways for trade in goods under the EU-UK Trade and Cooperation Agreement ("EU-UK TCA"). Bilateral trade between the UK and EU will be duty free and quota free provided the relevant...more
1/4/2021
/ Cooperation Agreement ,
Corporate Counsel ,
Customs ,
EU ,
Exports ,
Imports ,
Tariffs ,
Trade Agreements ,
UK ,
UK Brexit ,
Value-Added Tax (VAT) ,
WTO
After countless deadlines have come and gone, with a deal 90% done but three intransigent sticking points, on 24 December 2020 the UK and EU finally announced "agreement in principle" had been reached on their future...more
On 7 December 2020, the EU Council adopted a landmark decision and a regulation setting up for the first time a global human rights sanctions framework for the EU. The EU can now respond to serious human rights violations and...more
The EU has recently made certain notable EU asset freeze designations in relation to Belarus1 and Syria, focusing on various government officials – including President Alexander Lukashenko in Belarus -
The Belarusian and...more
11/11/2020
/ Asset Freeze ,
Belarus Sanctions ,
Due Diligence ,
Economic Sanctions ,
EU ,
Exemptions ,
Member State ,
National Security ,
State-Owned Enterprises ,
Syria ,
Travel Ban
The European Commission and the EU's Foreign Policy High Representative have put forward a proposal for a new, non-country-based sanctions programme to address human rights violations and abuses with asset freezes and travel...more
On 14 October 2020, the EU designated under its asset freeze six Russian officials and one research institute, in response to the poisoning of Russian opposition leader Alexei Navalny in August 2020. Separately, it also...more
On 2 October 2020, the EU adopted sanctions against Belarus in response to the repression and intimidation against peaceful demonstrators, opposition members and journalists in the wake of the 9 August 2020 presidential...more
On 28 September 2020, the European Commission unveiled an ambitious Action Plan with 30 concrete actions intended to make the EU customs union smarter, more effectively digital, and more agile by end 2025. Key aims (once...more
On 30 July 2020, the EU designated the first individuals and entities under its 2019 sanctions framework targeting parties involved in cyber-attacks that undermine the EU’s integrity, security and economic competitiveness....more
8/10/2020
/ Asset Freeze ,
China ,
Cyber Attacks ,
Cyber Threats ,
Economic Sanctions ,
EU ,
Intellectual Property Protection ,
List of Specified Persons (LSP) ,
Member State ,
Misappropriation ,
Russia ,
Travel Ban
On 6 July 2020, the UK adopted its first autonomous sanctions regime, imposing asset freezes and travel bans on 47 individuals and two entities across the world accused of serious human rights violations. The new regime marks...more
The UK sanctions authority, the Office of Financial Sanctions Implementation (OFSI), has announced its first multi million pound fine since its establishment in 2016. The fine confirms OFSI’s increasing enforcement activity...more
The European Commission has launched a consultation to help shape the next Generalised Scheme of Preferences ("GSP") from 2024. Stakeholders have until 3 June 2020 to comment....more
On 31 March 2020, the Governments of France, Germany, and the United Kingdom (the so-called "E3") confirmed that the first transaction was completed through the Instrument in Support of Trade Exchanges ("INSTEX"),...more
4/3/2020
/ Economic Sanctions ,
EU ,
Exports ,
Food Supply ,
Imports ,
INSTEX ,
Instrument for Supporting Trade Exchanges (INSTEX SAS) ,
Iran ,
Joint Comprehensive Plan of Action (JCPOA) ,
Medical Supplies ,
Payment Systems ,
Swiss Banks ,
United States
In an effort to secure continued supply of goods within the EU during the COVID-19 crisis, the EU has taken a number of initial actions with a focus on essential health products and food. So far, these EU actions include 1)...more
This is a special newsletter with our selection of key EU customs developments in 2019. It is not intended to provide an exhaustive summary.
...more
1/29/2020
/ Administrative Proceedings ,
Classifications of Goods ,
Country of Origin ,
Customs ,
Draft Implementation Regulations ,
EU ,
European Commission ,
Fair Trade Agreements (FTA) ,
Nomenclature ,
Tariffs ,
Trial Court Orders ,
UK Brexit ,
Valuation
France, Germany and the United Kingdom, known as the “E3”, announced on 14 January 2020 that they had triggered the dispute resolution mechanism under the Joint Comprehensive Plan of Action (“JCPOA”) due to concerns about...more
1/17/2020
/ China ,
Dispute Resolution ,
E3+3 ,
Economic Sanctions ,
EU ,
Failure to Perform ,
France ,
Germany ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Russia ,
UK ,
UN Security Council ,
United Nations ,
Winding Down
On 17 May 2019, the EU put in place a new legal framework for sanctions targeting malicious cyber activities from outside the EU that threaten the Union or its Member States. The aim is to enhance the EU's cyber resilience...more
On May 8, 2019, following Iran's announcement that it intends to suspend certain nuclear proliferation-related commitments under the Joint Comprehensive Plan of Action (JCPOA), the United States issued a new Executive order...more
5/14/2019
/ Blocking Sanctions ,
Blocking Statutes ,
CAPTA List ,
China ,
Economic Sanctions ,
EU ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
France ,
Germany ,
IFCA ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Metals ,
Nuclear Power ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Prohibited Transactions ,
SDN List ,
Steel Industry ,
Suspensions ,
Trump Administration ,
UK ,
Waivers
On May 2, 2019, claimants began filing lawsuits for the first time under Title III of the Helms-Burton Act against third parties alleged to be "trafficking" in property of US nationals confiscated by the Cuban Government...more
5/9/2019
/ Blocking Statutes ,
Canada ,
Confiscated Property ,
Cuba ,
EU ,
FSCS ,
Helms-Burton Act ,
Orders of Prohibition ,
Personal Remittance Caps ,
Sanction Suspensions ,
Statute of Limitations ,
Third-Party ,
Title III ,
Trafficking ,
Travel Restrictions ,
Trump Administration ,
UK ,
US Department of State
The United Kingdom (UK) leaving the European Union (EU) will inevitably result in difficulties for businesses using UK content in their products for export under EU Free Trade Agreements, or for UK businesses using EU content...more
4/2/2019
/ Component Parts Doctrine ,
Country of Origin ,
EU ,
European Commission ,
Exports ,
Free Trade Agreements ,
No-Deal Brexit ,
Suppliers ,
Supply Contracts ,
Tariffs ,
UK ,
UK Brexit
On 14 March 2019, the EU Horizontal Safeguard Regulation 2019/287 ("HSR") entered into force to streamline the implementation of bilateral safeguard measures in EU trade agreements concluded with third countries....more
With Brexit looming, the UK's autonomous sanctions policy is slowly taking shape. This month saw the publication of regulations setting out the post-Brexit UK sanctions regimes for Iran, Burma and Venezuela, which will come...more
3/4/2019
/ Asset Freeze ,
Blocking Statutes ,
Burma ,
Economic Sanctions ,
EU ,
General Licenses ,
Information Sharing ,
Iran ,
Joint Comprehensive Plan of Action (JCPOA) ,
No-Deal Brexit ,
Office of Financial Sanctions Implementation (OFSI) ,
Ownership Rules ,
Reporting Requirements ,
Right to Control ,
Sanctions and Anti-Money Laundering Act 2018 (SAMLA) ,
UK ,
UK Brexit ,
Venezuela
EU Customs Policy -
Amendments to the UCC and related legislation -
Key developments relating to proposed and adopted amendments to the Union Customs Code (UCC) in 2018include the following:
In March 2018, the...more
2/19/2019
/ Classification ,
Customs ,
EU ,
Fair Trade Agreements (FTA) ,
GSP Regime ,
Intellectual Property Protection ,
No-Deal Brexit ,
Tariffs ,
Trade Agreements ,
UK Brexit ,
Uniform Commercial Code (UCC)
On 31 January 2019, France, Germany and the United Kingdom (the "E3") announced the registration in France of INSTEX SAS ("Instrument for Supporting Trade Exchanges"), which is a special purpose vehicle aimed at facilitating...more
2/14/2019
/ AML/CFT ,
Blocking Statutes ,
EU ,
FATF ,
France ,
Germany ,
INSTEX ,
International Atomic Energy Agency ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Special Purpose Vehicles ,
UK ,
United Nations