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Ross Evans

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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…

The UK has designated six individuals as subject to financial sanctions and asset freeze measures under the Syria (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/792). The designated persons are: Muhammad Bara AL-QATIRJI,Faisal AL-MIQDAD,Luna AL-SHIBL,Malik ALIAA,Yasser Hussein IBRAHIM,Zaid SALAH. Separately, two entries under the UK’s Iran (Nuclear) financial sanctions regime have been amended. These entries have been added to the UK sanctions list and to the Office of Financial Sanctions Implementation’s Consolidated list of financial sanctions targets.

Following the designations announced 18 February (see our recent post), the UK has designated 5 further individuals under the Myanmar/Burma sanctions regime: Tin Aung SanMaung Maung KyawAung Lin DweMoe Myint TunYe Win Oo The UK has also updated the listing details for Min Aung Hlaing (previously designated, and remaining subject to asset freeze measures). In addition, the existing designation for Bi Sidi Souleman under the UK’s Central African Republic sanctions regime has also been amended.

UK sanctions On 18 February 2021, the UK announced sanctions against Myanmar military generals for serious human rights violations, which come into force immediately. The Foreign Secretary Dominic Raab has announced there are 3 individuals subject to immediate asset freezes and travel bans for serious human rights violations by the military and police force (these are in addition to the current 16 sanctioned individuals). These individuals are: General Mya Tun Oo (Minister of Defence)Lt General Soe Htut…