Author

Sunny Mann (UK)

Browsing

On 21 June 2021, the EU and UK announced coordinated sanctions against specified Belarusian individuals and entities. This follows the forced landing of a commercial aircraft in Belarus and subsequent detention of a Belarusian journalist, and suggests that the UK is continuing to align its sanctions regime with key allies following Brexit. The sanctions were further coordinated with the US and Canada. The designated parties will be subject to asset freezes, whilst individuals will be subject to…

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…

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…