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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

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

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

Podcast: U.S. Sanctions and Their Impact on Non-U.S. Businesses

In this podcast, Akin Gump’s international trade partners Mahmoud Baki “Mac” Fadlallah (Dubai), Jasper Helder (London) and Wynn Segall (Washington, D.C.) discuss three pivotal regions related to U.S. sanctions under the...more

President Trump Issues New Iran Executive Order and Reimposes First Set of Sanctions Following JCPOA Withdrawal

• On August 6, 2018, following President Trump’s decision to withdraw the United States from the JCPOA, the U.S. government announced the reimposition of sanctions on Iran’s automotive sector, its trade in gold and precious...more

EU Trade Update: Trade Aspects of the July 2018 U.K. Government White Paper on the Future U.K. EU Relationship

• The White Paper sets out in detail the shape and scope of the U.K.’s desired future “association” relationship with the EU post Brexit. The U.K. government hopes that it will accelerate negotiations with the EU with a view...more

President Trump Announces U.S. Withdrawal from JCPOA; U.S. Sanctions on Iran will be Re-imposed Following Wind-Down Periods

• The U.S. government has withdrawn from the Iran Nuclear Deal and reverted sanctions to the status quo ante by re-imposing secondary sanctions that restrict non-U.S. persons from engaging in a broad range of business in...more

OFAC Issues Updated General Licenses Clarifying and Extending Authorized Activities with Russian Sanctioned Entities

• On May 1, 2018, OFAC issued General License 13A authorizing the divestment or transfer of certain debt, equity or other holdings issued by EN+ Group, GAZ Group or United Company RUSAL PLC, as well as entities in which such...more

OFAC Issues General License Expanding and Extending Authorized Activities with RUSAL Until October 23, 2018

Today, OFAC issued General License 14, authorizing U.S. persons to engage in specified transactions related to maintenance or wind down of operations, contracts or other agreements involving RUSAL until October 23, 2018,...more

OFAC Sanctions Leading Russian Businessmen, Government Officials and Companies

• On April 6, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) placed seven prominent Russian businessmen, 12 companies, 17 senior Russian government officials, and a state-owned Russian...more

EU and UK Transition Period Trade Terms

• The U.K. and the EU have agreed on the substantive trade elements of the legal text set to govern the U.K.’s withdrawal from the EU (the “Withdrawal Agreement”). If the other outstanding elements of the Withdrawal Agreement...more

EU Trade Update

• European Commission publishes survey on concept of “Specially Designed for Military Use,” and issues request for input for possible EU commercial policy measures targeting the United States • Netherlands introduces...more

UK Jury Verdict Clarifies “Adequate Procedures” Under UK Bribery Act

In an important decision given on February 21, 2018, a jury in English court proceedings has considered for the first time what “adequate procedures” should be for the purpose of a defense to the corporate offense of failing...more

European Court of Justice: Intercompany Pricing Cannot Be Used For EU Import/Customs Purposes If Subject to Adjustments

• A recent judgment of the European Court of Justice for bars the use of intercompany transfer prices for EU imports and EU customs duty purposes if (as is commonly the case) these are subject to retroactive adjustments. ...more

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