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Sunny Mann

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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…

As part of its updated 2020 Industrial Strategy, the EU Commission noted that the pandemic has highlighted the trading bloc’s technological and industrial strategy dependencies, which need to be analysed and addressed as part of Europe’s economic recovery. The Commission presented the findings of a review of products imported into the EU on which the EU is highly dependent in notably sensitive sectors, along with the results of six in-depth reviews providing insights on the origin…

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 European Parliament has adopted a non-binding resolution in the event of Russian troops entering Ukraine. The resolution proposes that imports of oil and gas from Russia to the EU be immediately stopped, that Russia should be excluded from the SWIFT payment system (used for international bank transfers) and that assets in the EU of oligarchs close to the Russian authorities and their families should be frozen in the event of Russian troops entry into…

The UK has issued the Global Anti-Corruption Sanctions Regulations 2021 (the “Regulations“), which came into force on 26 April 2021. These Regulations are designed to ensure that sanctions relating to serious incidents of corruption are enforced. The Regulations will give the government the power to impose asset freezes on designated persons or those dealing with them, with the aim of preventing the UK from being used as a “haven for dirty money.” This is the first time…

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…