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Compliance

EU publishes ‘guidance’ on controls on Information Security items and the Cryptography Note

On 25 October 2016 the EU published its brief Guidance Note 1/2016 concerning FAQ on controls of ‘Information Security’ items and implementation of the Cryptography note exemption.

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

In this first post on a new series, we will discuss the most debated topic of the proposal thus far, which is the establishment of specific human rights based controls on cyber-surveillance technologies. By Bert Gevers, Megan Gajewski Barnhill & Jochen Vankerckhoven, 28 October 2016. On 28 September 2016 the EU Commission published its proposal for a modernization of the EU export…

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Tipping the Scales: Balancing US Trade Controls’ Restrictions on Access with EU Labor and Privacy Rules (III)

In last month’s post, we discussed the legitimacy of the collection and processing of employee data for the purpose of complying with US trade controls regulations, and in particular with restrictions on access to controlled technical information. As a consequence of these restrictions, European employers may be required to provide to the US State Department certain information relating to employees…

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Tipping the Scales: Balancing US Trade Controls’ Restrictions on Access with EU Labor and Privacy Rules

European entities that receive controlled technology from US parties often find themselves with a bit of a quandary: how to balance the US trade controls’ restrictions on access to controlled technical information with local privacy and labor rules. This series of posts will describe the issues that arise under the relevant US and EU rules and strategies that can be…

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Linking trade control compliance and customs compliance programs

With the introduction of the new Union Customs Code (UCC) on 1 May 2016, the status of Authorized Economic Operator (AEO) became the cornerstone of the revised customs legislation in the EU. By Bert Gevers, Jack Nuijten and Yassine El Bojaddaini This concept of certified traders was first introduced in the EU in 2008 in order to enhance international supply…

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What about the banks – are we seeing the first signs of genuine business with Iran?

There is growing frustration in Iran and Europe about the slow pace of reconnecting Tehran to the global financial system. This even led to a recent joint statement by the P5 +1 nations that negotiated the JCPOA explicitly underlining that they will not “stand in the way of permitted business activity with Iran, and will not stand in the way…

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Trade controls and M&A: how to preserve the value of your transaction?

The substantial risk associated with the expansion and enhanced enforcement of trade controls has a direct impact on due diligence in cross-border M&A transactions Non-compliance by the target with international trade laws and regulations may not only have a material adverse impact on the value of the transaction, it may also trigger the vendor and even buyer’s liability, and affect…

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