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Sunny Mann

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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 1 April 2021, the UK government announced additional measures targeting the Myanmar regime’s economic interests. Further to the 25 March 2021 announcement targeting Myanmar Economic Holdings Ltd (MEHL), the UK has added Myanmar Economic Corporation (MEC) to its Global Human Rights sanctions regime. The UK cited credible evidence that MEC had contributed funds to the Myanmar military who have allegedly committed widespread human rights violations in Myanmar. The sanctions impose an asset freeze against MEC and its subsidiaries as…

On 25 March 2021, the UK Government announced further measures targeting the Myanmar regime, adding Myanmar Economic Holdings Public Company Ltd (MEHL) to the Global Human Rights financial sanctions regime for its alleged involvement in human rights violations against the Rohingya. MEHL has been added to the UK Sanctions List and to the Office of Financial Sanctions Implementation’s consolidated list of financial sanctions targets. The UK also named 40 of MEHL’s subsidiaries in its Sanctions List, targeting entities operating in a broad…

On 22 March 2021, the EU imposed restrictive measures on eleven individuals and four entities in relation to alleged human rights violations, including: four individuals and one company with links to the large-scale arbitrary detentions of Uyghurs in Xinjiang;two individuals and one company in the DPRK, responsible for implementing repressive security policies and other human rights violations;two officials in Libya and the armed Libyan militia, responsible for serious human rights abuses including extrajudicial killings;two Russian individuals involved in violations of LGBTI…

On 22 March 2021, the UK Government added four individuals and one entity to the Global Human Rights financial sanctions regime, in relation to alleged human rights violations taking place in Xinjiang, China. Four Chinese government officials and a Xinjiang security body have been added to the UK sanctions list and to the Office of Financial Sanctions Implementation’s consolidated list of financial sanctions targets. These measures were announced in coordination with Canada and the United States, and in parallel…

Further to our previous blog post, the EU has responded to the recent military coup in Myanmar with restrictive measures on eleven individuals. This adds to pre-existing restrictive measures that have been in place since April 2018, as detailed in our previous blog post. These measures included an embargo on arms and equipment that can be used for internal repression, an export ban of dual use goods for use by the military and border guard police, and export restrictions…

In an 18 March 2021 statement released by the German Foreign Ministry, the Group of Seven (G7) nations have announced that they remain fully committed to the implementation of sanctions on Russia over the annexation of the Crimean Peninsula. The group’s Foreign Ministers also reaffirmed their unwavering support for and commitment to the independence, sovereignty and territorial integrity of Ukraine, and denounced

The EU is reportedly set to approve its first round of sanctions against officials responsible for the military coup in Myanmar on 22 March 2021. French Foreign Minister Jean-Yves Le Drian confirmed this was on the agenda at the next meeting of the EU Foreign Affairs Council whilst addressing the French Senate earlier this week. Whilst technical discussions are being finalised in Brussels, it is understood that the measures will target companies “generating revenue for,…

On 10 March 2021, the Government published new guidance on the government processes on the issue of monetary penalties for breaches of financial sanctions (see here). This guidance applies from 1 April 2021 and from this date will replace the April 2018 guidance (see our previous blog post on this guidance here). In the interim, the current guidance will remain applicable. The updated guidance incorporates some of the lessons learned through OFSI’s monetary penalty cases since April 2018 and…

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…