Brexit: what export controls impacts are we seeing so far and what can we expect?

For trade Brexit

  1. Dual Use Goods

When the UK became a 'third country' according to European Union (‘EU’) law, licence-free movement of dual-use goods to and from the EU ceased to apply. The immediate impact was mitigated by the introduction of a number of new authorisations and the UK Export Control Joint Unit ('ECJU') has published extensive guidance on exporting controlled and dual-use items after Brexit.

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Posted on 23/02/2021

Brexit: What it means for UK sanctions

Sanctions blog pic 25.01.21

As of 23.00 GMT on 31st December 2020, the UK no longer implements EU sanctions, but instead UK sanctions. The UK Sanctions and Anti-Money Laundering Act 2018 is now the legislation used to impose, lift, amend, and update sanctions and anti-money laundering (AML) regimes in the UK: these include financial sanctions, immigration sanctions, trade sanctions, aircraft sanctions, shipping sanctions, and money laundering regulations.

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Posted on 25/01/2021

UK to resume military-related exports to Saudi Arabia and coalition partners


On 20th June 2019, a judgment of the Court of Appeal concluded that British arms sales to Saudi Arabia were unlawful. The judgement accused ministers of ignoring whether airstrikes that killed civilians in the Yemen civil war broke humanitarian law, making the UK arms-related sales to Saudi Arabia non-compliant with UK trade law

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Posted on 23/07/2020

US and China Export Controls: An Update


Update to Part 744 of the EAR

On June 29th, the final Rule on “Expansion of Export, Reexport, and Transfer (in-Country) Controls for Military End Use or Military End Users in the People's Republic of China, Russia, or Venezuela,” will come into effect.

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Posted on 25/06/2020

Trump Imposes New Sanctions on Russia


On Friday, 2 August 2019, after growing pressure from the United States Congress to take further punitive action, Trump Administration announced new economic sanctions against Russia for the alleged use of banned chemical weapons in an attempt to poison a former Russian spy, Sergei Skripal, and his daughter, Yulia, in Salisbury, United Kingdom (U.K.), in March 2018.

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Posted on 12/08/2019

New OFAC Reporting Requirement for Any Sanctions Rejected Transaction


The United States (U.S.) Office of Foreign Assets Control (OFAC) has imposed a new reporting requirement on U.S. persons for transactions or property “blocked” (property being frozen) or “rejected” (declining of financial transactions or transactions in goods or services), “where processing or engaging in the transaction would nonetheless violate” OFAC sanctions.

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Posted on 01/08/2019

China’s Ministry of Commerce Introduces an Unreliable Entity List


On 31st May 2019, China's Ministry of Commerce ("MOFCOM") announced that the country will introduce an 'Unreliable Entity List' (UEL).

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Posted on 23/07/2019

Customs Alert Thailand – TCWMD Act updates



We would like to inform you that the Thai TCWMD Act (Trade Controls on Weapons of Mass Destruction related Items) has received Royal assent and will be effective on 1st January 2020. What to know? The TCWMD Act was published in the Royal Gazette on 30th April 2019.

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Posted on 04/06/2019

BIS Puts New Controls on Some Emerging Technologies


The United States Bureau of Industry and Security (“BIS”) has published regulations to implement changes agreed at the annual Wassenaar Arrangement (WA) Plenary to control “emerging technology” items under the Commerce Control List (“CCL”).

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Posted on 03/06/2019

Office of Foreign Assets Control (OFAC) Compliance Commitments Framework


On the 5th of May, the United States (US) Department of Treasury Office of Foreign Assets Control (OFAC) published new guidance on adopting a risk-based approach to manage sanctions compliance, including a suggested framework for a Sanctions Compliance Program (SCP).

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Posted on 10/05/2019