In 2021, the EU adopted an updated version of the EU Dual-Use Regulation, which establishes common standards for the control of dual-use item exports by EU member states. Among its new provisions, Regulation (EU) 2021/821...more
10/25/2024
/ Cybersecurity ,
Dual Use Goods ,
Due Diligence ,
EU ,
Export Controls ,
Exporters ,
Exports ,
Regulatory Agenda ,
Regulatory Requirements ,
Surveillance ,
Technology Sector
In a bold move to tighten its sanctions enforcement, the EU rolled out Directive 2024/1226, establishing minimum rules for defining criminal offenses and penalties related to the violation of EU sanctions. Effective May 19,...more
The EU is going extraterritorial, and it is doing so through private contract. It is a pretty neat trick.
As a general rule, EU regulations do not apply extraterritorially. This policy is a bit pointed, intended to stand...more
3/28/2024
/ Asset Freeze ,
Buyers ,
EU ,
European Commission ,
Exporters ,
Exports ,
Extraterritoriality Rules ,
Importers ,
Imports ,
Member State ,
Russia ,
Sanctions ,
SDN List ,
Ukraine
The EU plans to step up controls on its home grown technology. That is the short version.
The longer version is a (pretty dry) recitation of the proposed legislation and whitepapers that were published last week as the...more
On June 23, 2023, the EU released its 11th package of sanctions on Russia. This package is designed to improve enforcement with new anti-circumvention rules, new trade restrictions, and new designations. The...more
6/26/2023
/ Asset Freeze ,
Crude Oil ,
Economic Sanctions ,
EU ,
Export Controls ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
Supply Chain ,
UK ,
Ukraine
In response to Russia’s ongoing aggression in Ukraine, both the United States and the European Union have imposed additional sanctions and further restricted exports to Russia and Iran. These new controls span many...more
2/28/2023
/ Economic Sanctions ,
Entity List ,
EU ,
Export Controls ,
Exports ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions ,
UK ,
Ukraine
On Monday, February 13, 2023, the U.S. government will officially issue a stricter policy of denial for providing lower-tech items to Huawei.
Technological containment continues as the Netherlands and Japan move to impose...more
2/9/2023
/ Bureau of Industry and Security (BIS) ,
China ,
EU ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Direct Product Rule ,
Huawei ,
Japan ,
Licensing Rules ,
Semiconductors ,
Technology Sector ,
U.S. Commerce Department
Updated as of April 12, 2022 -
It has now been more than 40 days since the start of Putin’s brutal invasion of Ukraine. Today, following the recent revelations of the atrocities committed in Bucha, Ukraine by Russian armed...more
4/13/2022
/ Asset Freeze ,
Belarus Sanctions ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Transactions ,
G7 ,
General Licenses ,
Investment ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trading Restrictions ,
UK ,
Ukraine
Updated as of February 25, 2022 -
Key Takeaways of OFAC (Treasury) and BIS (Commerce) Actions -
Major Russian Banks Blocked from the U.S. Financial System. Six major Russian banks — VEB, Promsvyazbank (PSB), VTB Bank,...more
Updated as of February 25, 2022 -
Key Takeaways of EU and UK Recent Actions Against Russia and Ukraine Breakaway Regions -
The EU adopted the first tranche of sanctions restrictions targeting financial institutions, other...more
U.S. Comprehensive Sanctions Against the DNR and the LNR -
Scope: the DNR and LNR -
The new EO does not detail which parts of the Donetsk and Luhansk regions[1] are subject to the new U.S. sanctions. It is likely that...more
2/22/2022
/ Biden Administration ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
UK ,
Ukraine ,
United States ,
Vladimir Putin
Scope of the Proposed Regulation -
The Regulation would apply where a third country interferes in the legitimate sovereign choices of the Union or a Member State, by applying or threatening to apply measures affecting...more
2/15/2022
/ China ,
Coercion ,
Comment Period ,
Countermeasures ,
EU ,
European Commission ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Member State ,
Proposed Regulation ,
Russia ,
Trade Wars
Starting January 1, 2022, the use of E171 titanium dioxide as a food additive will be banned in Europe. The European Commission’s proposal to ban E171 in food products throughout the European Union was approved a few weeks...more
On July 26, 2021, the SEC announced the approval of a substituted compliance determination order with respect to security-based swap dealers and major security-based swap participants (SBS Entities) subject to regulation in...more
In May 2018 the United States announced the reinstitution of sanctions against Iran that had previously been lifted pursuant to the Joint Comprehensive Plan Action (“JCPOA”).
The U.S. sanctions on Iran that were revived...more
5/27/2021
/ Banks ,
Blocking Statutes ,
Corporate Counsel ,
EU ,
European Court of Justice (ECJ) ,
Financial Institutions ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Sanctions
On May 10, 2021, the EU adopted its new, revised version of Regulation (EC) No 428/2009 (the “Regulation”). It is widely acknowledged to be the first major reform to the structure of the EU’s export control regime since...more
On February 1, 2021, the Myanmar military overthrew the country’s democratically elected government and installed an army general as head of state, with a cadre of military officials and their allies running the government. ...more