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Andrew Rose (UK)

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For the second week of our Annual Compliance Conference, we discussed key trade compliance issues impacting our clients globally. Specifically, we discussed the trade policy response of the US, EU and UK to ever increasing geopolitical disruption, global strategies for handling sanctions regulators and enforcement, and key global sanctions and export controls developments. Trade policy response to geopolitical disruption – China and beyond – Tuesday 7 May Speakers: Tristan Grimmer (Partner, London), Sylwia Lis (Partner,…

Baker McKenzie’s Global Compliance News Blog published “Multijurisdictional: 2021 Virtual Global Trade Conference,” which can be viewed here.

Following coordinated designations of certain Belarusian individuals and entities earlier this week (see our previous post here), the EU has announced that further sector-based economic sanctions will come into force on 25 June 2021. The restrictions are implemented by Council Regulation (EU) 2021/1030 (the “Regulation“), which amends Regulation (EC) No 765/2006. The new sanctions target a broad range of technology and software, dual-use goods and technology, tobacco, petroleum and potash products, and financial services. The prohibitions apply regardless of…

On 11 June 2021, the Recast Dual-Use Regulation was published in the Official Journal of the European Union as Regulation 2021/821 (the “Regulation”). The Regulation, which comes into force on 9 September 2021, will replace the current Dual-Use Regulation introduced in 2009. Key changes include: Two new general export authorisations: The Regulation introduces a general export authorisation for intra-group transfers of dual use software and technology to specified countries for product development purposes, that is available where…

The scope of the two Open General Export Licences (OGEL) for security items has been further refined and amendments to the OGELs were on Wednesday (26 May 2021) published by the Department for International Trade in a Notice to Exporters. The updated OGELs permit the export of low risk information security items that rely on encryption technologies listed in Schedule 1 to each OGEL. The new Information Security OGELs cover a significantly wider range of items than the…

On 10 May, the Council of the European Union adopted a revised version of the EU’s Dual-Use Regulation. This is the first major reform to the structure of the EU’s export control regime since 2009. The text, which was passed by the European Parliament on 26 March, has been under negotiation for five years and was agreed in November 2020 (see our previous blog post). Key changes include two new general export authorisations, stricter controls on cyber-surveillance and technical assistance,…

The UK Export Control Joint Unit has published a revised guidance note on exporting military or dual-use technology. This guidance clarifies a number of common queries regarding technology exports, particularly around the use of cloud storage and remote data infrastructure through which information could be routed. The guidance also addresses the application of the special arrangements in Northern Ireland under the EU-UK Withdrawal Agreement. The guidance affirms the position on how key definitions and concepts in UK…

On 15 October, the EU imposed Designated Party controls on six individuals and one entity in Russia under the EU’s Chemical Weapons sanctions regime for their alleged involvement in the poisoning of Alexei Navalny with a nerve agent in August 2020. The EU separately designated one Russian individual under the Libya sanctions regime, for alleged breaches of the UN arms embargo against Libya. These individuals and entities are now subject to a travel ban and…