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
While EU countries reaffirm their commitment to the JCPOA, EU companies brace for impact
Although expected, President Trump’s decision to pull the US out of the JCPOA has triggered swift and concerned reactions from Europe. Despite the EU’s reaffirmed commitment to the JCPOA, it is yet unclear whether – and how – the Agreement will survive. … Keep Reading
They’re Back: US Nuclear Sanctions against Iran
United States is pulling out of the Joint Comprehensive Plan of Action (“JCPOA”). What does this mean going forward? … Keep Reading
Meet OFAC in Brussels and discuss the disruption of export control & sanction regimes by new technologies on 11 June 2018
The combination of innovation and digitization causes severe disruption to existing controls and regimes. New technologies have potential to disrupt if not evade traditional export control regimes and create significant challenges for businesses and regulators alike. … Keep Reading
Belgian companies brought to Court for illegal exports of chemicals to Syria
The Belgian customs authorities are suing three Belgian companies before the Criminal Court of Antwerp for what appears to be serious infringements of the restrictive measures imposed on Syria. The three companies concerned are all parties involved in the supply chain of a deal in chemical products: the producer, the company handling the administrative aspects of the transaction, and the… … Keep Reading