EU Commission issues notice to stakeholders on impact of Brexit
On 25 January 2018, the EU Commission issued a notice regarding the impact of Brexit on future movements of controlled goods. By Olivier Coulon, 26 January 2018 In its notice, the EU Commission recalls that, unless an agreement would provide for another date, the United Kingdom shall be treated as a third country as from 30 March 2019. The impact… … Keep Reading
Shipping Criminal Liability: the Difficult Position of the Transportation & Logistics Sector
On 23 November 2017, the Court of Amsterdam handed down its decisions in the case concerning the Dutch transportation company charged with breaching the military embargo against the Russian Federation. These decisions are the latest in a string of Dutch enforcement cases relating to the transit of military goods which have raised concerns within the transportation & logistics sector. In… … Keep Reading
Export Control Considerations: Beyond the Authorization
Your compliance obligations don’t end once an authorization is in hand. Determining whether and what authorizations are needed and ensuring that all required authorizations have been obtained are critical first steps in trade compliance, but compliance is a continuing process. By Megan Barnhill, Bryan Cave LLP, 8 December 2017 Review and Understand the Authorization A critical first step is to… … Keep Reading
Dutch Prosecutor Demands 80.000 Euro Fine in New Sanctions Enforcement Case
On 9 November 2017 another case concerning the breach of sanctions was brought before the Dutch court. This case is the latest example of an increased enforcement effort of the Dutch authorities. From the information published on the government website, it appears that the public prosecution (the Prosecution) has demanded that a logistics provider (the Defendant) will be fined an… … Keep Reading
Trump Administration Unveils Strategy on Iran
After a number of tweets and news articles indicating that President Trump intended to make major changes to U.S. policy regarding Iran, President Trump formally announced on Friday, October 13, his Administration’s strategy on the subject. The strategy announcement itself resulted in limited changes to U.S. sanctions and no change (for now) with respect to the role of the United… … Keep Reading
Change is Coming: China Proposes New Export Control Law
On June 16, 2017, China’s Ministry of Commerce (“MOFCOM”) released for public comments the draft Export Control Law of the People’s Republic of China (the “ECL”). The ECL, once enacted, could substantially change China’s current export controls regime and affect the business operations of EU and U.S. multinationals within and outside of China. By David Stepp, Clif Burns & Zhiwei… … Keep Reading
Two-Year Prison Sentence Demanded in Dutch Sanctions Enforcement Case
Another case that seems to betray a tougher line of sanctions enforcement in the Netherlands has emerged. On 21 August 2017, the Dutch public prosecution (the Prosecution) demanded two years of imprisonment for a managing director of a Dutch company which had dealings with Iran (the Defendant). In this case, brought before the Court of Den Bosch, the Prosecution has… … Keep Reading
EU Commission and Member States to fight any extraterritorial application of the new US sanctions
What about the extra-territorial application of the sanctions in the “Countering America’s Adversaries Through Sanctions Act” (CAATS) signed by President Trump on 2 August 2017? … Keep Reading