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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

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

Export Controls Enforcement by the Dutch Court | Part 2: The Case of the Airline Company

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

Export Controls Enforcement by the Dutch Court | Part 1: The Case of the Logistics Provider

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

Applicability of U.S. Export Controls on Emerging Technology

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

Dual-use application of Key Enabling Technologies

A recent study report (accessible here), originally ordered by EASME (the European Executive Agency for SMEs), addresses the dual-use potential of Key Enabling Technologies (KETs). The report deserves the particular attention of SMEs involved in KET research and development, because the dual-use potential of these technologies, if realized, is likely to bring the activities of these SMEs within the scope… … Keep Reading

The Rosneft Judgment: CJEU upholds and clarifies Russia sanctions

In a recent judgement of 28 March 2017 (Case-72/15), involving PJSC Rosneft Oil Company (Rosneft), the Court of Justice of the European Union (CJEU) has ruled on the validity of the EU sanctions against Russia and clarified some important issues concerning the scope of these sanctions. The judgement has drawn attention, because the interpretation and scope of the sanctions has… … Keep Reading

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