EU Council finally agrees negotiating mandate for the recast of the EU Dual Regulation
After the release of the EU Commission’s proposal in 2016 it took the Council almost three years of discussions to agree on this negotiating mandate (https://www.consilium.europa.eu/media/39555/mandate-for-negociations.pdf). The Council prefers a lighter’ version of the recast focusing primarily on harmonization and simplification. Now it is up to the EU Council, Parliament & Commission to agree on a new text. … Keep Reading
Belgium (finally) implements sanctions for violation of the EU Blocking Regulation
Last week, the Belgian Act implementing the EU Blocking Regulation was published in the Belgian Official Gazette (see here). … Keep Reading
EU adopts sanctions regime on cyber-attacks
On 17 May 2019, the EU adopted a brand new sanctions regime to deter and respond to cyber-attacks. This follows the adoption, on June 2018, by the European Council of conclusions outlining the necessity to strengthen the EU ability to address cyber threats originating from outside the EU. … Keep Reading
Don’t be Caught Off Guard: Huawei Entities Added to US Entity List
Effective 16 May 2019, exports and reexports by non-US parties are included within the scope of the Entity List restrictions imposed by the US Government against Chinese company Huawei and its non-US subsidiaries. … Keep Reading
There Are So Many US Restricted Party Lists, Do I Really Need to Search Them All?
Several circumstances may trigger the need for non-US parties to conduct restricted party screening against the various lists published by the US government. Deciding whether screening is useful, and which lists to screen against, depends upon the particulars of the business activity or contemplated transaction. The increasing prevalence of secondary sanctions from the United States makes screening against US lists… … Keep Reading
EU to Amend Union General Export Authorization in the Event of a No Deal Brexit
From time to time, a tiny flash illuminates the sombre Brexit front. One such flash is the proposal by the EU Commission to add the UK to the list of destinations covered by the Union General Export Authorization (EU001) for dual-use goods if there is a no deal Brexit on 29 March 2019. This move may prove significant as it… … Keep Reading
Adoption of New EU Legislation and Recent National Cases in the Fight Against Chemical Weapons
In the wake of the gruesome events in Syria authorities at the national and international level are stepping up action against chemical weapons proliferation. It would be a mistake to assume that the implications of this development are limited to either the Syrian theatre or chemical weapons as such. … Keep Reading
90-Day Wind Down Period Expires; First Wave of US Secondary Sanctions Against Iran Re-Imposed
As reported in our earlier post, as part of the US Government’s announcement that the United States was exiting the Joint Comprehensive Plan of Action (“JCPOA”), the US set out separate 90-day and 180-day time frames for the wind down of activities consistent with the sanctions relief in the JCPOA, following which the secondary sanctions lifted pursuant to the JCPOA… … Keep Reading