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Sunny Mann

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On 7 October 2020, the European Commission adopted the revised Annex I (the “Dual-Use List“) to Regulation 428/2009 (the “Dual-Use Regulation“) (see here). The new Dual-Use List came into force on 15 December 2020. The Dual-Use List is refreshed on an annual basis to take into account updates to international non-proliferation regimes and export control arrangements. The latest updates reflect changes from reviews carried out by the Wassenaar Arrangement in particular, and also from reviews by…

The Department for International Trade has revealed in a notice to exporters that HMRC has received settlements totalling £700,368.01 for export control violations between March and September 2020.Fines of up to £211,250 were issued to exporters across 19 settlement actions for unlicensed exports of dual use goods, military goods and related activity controlled by the Export Control Order 2008. This is the highest annual total for export control fines to date.HMRC has a discretionary power to impose…

The UK Department for International Trade has recently published guidance on how the UK will transpose and implement the EU Blocking Regulation (Council Regulation (EC) 2271/96) post-Brexit. The EU Blocking Regulation seeks to counter the extra-territorial impact of certain US sanctions (the “proscribed US sanctions”), currently in respect of Iran and Cuba (please see our previous blog post on updates of the EU Blocking Regulation in respect of Iran here). During the transition period, the EU…

The EU announced last week that the UK would be added to its list of safe countries to export ‘dual-use items’. Following the UK’s exit from the EU, the UK is no longer a Member State of the EU since 31 January 2020 and the EU law will cease to apply to the UK after the end of a transition period on 31 December 2020. As a result, the export of ‘dual-use items’ from the…

On 16 October 2020, the Export Control Joint Unit (ECJU) published Notice to Exporters 2020/14 to remind relevant exporters to sign up for the EU dual-use open general export licence (OGEL) before the end of the Brexit Transition Period. This OGEL will be required to export dual-use items from the UK to any EU Member State and the Channel Islands from 1 January 2021. It is not required to export dual-use items to the EU during the Transition Period…

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…

The European Council has designated 40 individuals under its Belarus sanctions regime, amending Council Regulation (EC) 765/2006. In the UK, the Office of Financial Sanctions Implementation (OFSI) has accordingly updated the consolidated list. 5 of these individuals were already sanctioned under the UK’s Global Human Rights regime and are now subject to an asset freeze under both the UK and EU regimes. OFSI has also updated information for a further 4 individuals under the UK regime, bringing the…

On 9 October 2020, the Office of Financial Sanctions Implementation (OFSI) published its Annual Review, providing an overview of OFSI’s activities in the financial year April 2019 to March 2020. A copy of the Annual Review is available here. In addition, OFSI has reminded UK businesses that they must report any frozen assets they hold by 16 October 2020. Statistics In 2019-2020, OFSI received 140 reports of potential financial sanctions breaches, an increase from 99 previously. The…

On 29 September 2020, the Office of Financial Sanctions Implementation announced that 8 Belarusian officials, including Alexander Lukashenko, his son Victor, and other senior Belarusian government officials, have been subjected to sanctions (asset freezes and travel bans) under the UK’s autonomous Global Human Rights sanctions regime. This regime was introduced earlier in 2020 as a “Magnitsky-style” regime, and is the first autonomous sanctions regime adopted by the UK following its departure from the EU. For…

On 19 August 2020, members of the European Council held a video conference to discuss the situation in Belarus following the presidential election on 9 August 2020. The President of the European Council stated that the elections in Belarus were “neither free nor fair”, did not meet international standards and that the EU did not recognize the results. It was announced that the EU would shortly impose sanctions on a substantial number of individuals responsible…