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
The Countering America’s Adversaries Through Sanctions Act (the CAATS Act) of August 2, 2017 impacts sanctions related to Russia, Iran and North Korea. Key among the changes is that it takes discretion out of the hands of the U.S. President to lift or change certain existing sanctions, particularly the sectoral sanctions imposed against Russia. Keep Reading
The unprecedented restrictive measures which Saudi Arabia, the U.A.E., Bahrain, and Egypt have imposed on Qatar last month could pose a greater challenge to international business than you might expect. The measures are difficult to navigate, making their scope opaque. Once you have taken the trouble to familiarize yourself with the activities that are being targeted, it will become clear… Keep Reading
In our previous post, we discussed the export controls enforcement case brought against a logistics provider. At the same date, the same court also issued a judgment against an airline company that had acted as a carrier of certain military goods. (Rechtbank Noord-Holland, nr. 15/994178-17, 24 April 2017). This second case contains some observations by the Court that are worth highlighting… Keep Reading
Unlike in the US, few European countries disclose detailed records of the enforcement of export control regulations. The Netherlands are no exception to this rule. For their guidance, economic operators basically will have to depend on the odd court case. Remarkably, a Dutch court recently rendered two separate judgments concerning export controls enforcement at the same date. By Gerard Kreijen,… Keep Reading
Will the Trump administration stick to or break with established US trade control policies and what could be the implications for our trade with Russia and Iran? Can we predict the consequences of a ‘hard Brexit’ and will it be possible for EU companies to anticipate? How do trade controls relate to the IT & Communications sector and what are… Keep Reading
As discussed in our previous post, the report published earlier this year by the EASME regarding the dual-use potential of certain Key Enabling Technologies (KETs) highlights the importance for companies in this area to be aware of the possibility of such technologies being or becoming subject to control under the EU Dual Use Regulation. By Megan Gajewski Barnhill & Roland… Keep Reading
Deciding to whom to submit a voluntary disclosure is also important. US as well as EU businesses should realize that in some cases more than one set of laws and regulations may apply. By Susan Kovarovics, Gerard Kreijen & Jochen Vankerckhoven, 15 May 2017 For instance, if items are controlled under EU export controls and subject to EU trade sanctions,… Keep Reading