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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

Opposites attract: linking HS and ECN classification

On 16 January 2017, the European Commission published its latest update of the TARIC CN-DU Correlation Table which establishes links between the customs classification codes (HS/CN) and export control classification codes (ECN). By Bert Gevers, Yassine el Bojaddaini & Megan Gajewski Barnhill , 21 February 2017. As this correlation table sometimes confuses exporters when determining whether an item is controlled for… … Keep Reading

U.S. Uses CFIUS Regulatory Authority to Prohibit Transaction Between Two German Entities

U.S. law provides the President with broad authority to prohibit transactions that he deems to present a national security threat to the United States. In this context, national security concerns may, but need not, involve information that is trade-controlled or classified. By Jennifer Kies Mammen and Gerard Kreijen , 16 February 2017 At the end of 2016, President Obama used this power to… … Keep Reading

US Leaves JCPOA Intact But Is Still Ratcheting Up Sanctions Against Iran

When the United States lifted its nuclear-related sanctions as part of its Implementation of the Joint Comprehensive Plan of Action (JCPOA) in January 2016, it left in place several other sanctions mechanisms that could be implemented against Iran. On February 3, following Iran’s tests of certain ballistic missiles, the United States designated twenty-five (25) additional individuals and entities as Specially Designated… … Keep Reading

Snapback: The More You Know, the Better Prepared You Can Be

The possibility of a snapback of the nuclear sanctions against Iran has created uncertainty since before Implementation Day of the Joint Comprehensive Plan of Action (JCPOA) in January 2016. Now as we near the one year anniversary of the implementation of the JCPOA, uncertainty seems to loom larger as we also face a new US President and Administration. By Susan… … Keep Reading

Modernization of the EU export control system: What’s next ? (II)

As discussed in our earlier post on the modernisation of the EU Dual-Use Regulation, it is the revised ‘catch-all’-provision that most worries exporters. The inclusion of human rights criteria, the corner stone of the new ‘human security’ approach in the Dual-Use Regulation, risks to lead to new uncertainties for exporters (and their national regulators). … Keep Reading

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