Office of Foreign Assets Control (OFAC) Compliance Commitments Framework

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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

No Deal Brexit: New OGEL Published for Dual-Use Exports to the EU

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The Department for International Trade published a new Open General Export Licence (OGEL) on 1st February 2019 to cover the export of controlled dual-use items to EU Member States after Brexit. The licence will come into force at 11pm on 29th March 2019, if the UK leaves the EU without a deal.

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Posted on 05/03/2019

Modernising Your Compliance Programme Event – 07 December 2018

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The Deloitte Regulatory Risk team are excited to inform you that we will be holding an event focused on modernising your compliance programme at our London office on 07 December 2018.

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Posted on 05/11/2018

Brexit and export controls: the ‘no deal’ scenario

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The Export Control Joint Unit (ECJU) of the Government of the United Kingdom has released a guidance document detailing the effect of exporting controlled goods in a ‘no deal’ Brexit scenario. 

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Posted on 31/08/2018

UK Government Relaxes Restrictions on Arms Exports to Argentina

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The UK government has changed its policy on arms exports to Argentina. On 27 June 2018, the government announced that it would consider granting export licences for military and dual-use goods and technology to military end users in Argentina, so long as such items were not judged to enhance Argentine military capabilities.

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Posted on 30/07/2018

New Merger and Takeover Rules for UK Exporters

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On 11th June, in an effort to strengthen national security, the UK Government adopted a set of new regulations to reinforce its merger and takeover scrutinising ability. 

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Posted on 06/07/2018

Iran, the Joint Comprehensive Plan of Action, and International Trade

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On 8th May 2018 President Donald Trump announced the United States’ (U.S.) withdrawal from the Joint Comprehensive Plan of Action (JCPOA) and renewal of U.S. far reaching sanctions. The Agreement, signed in 2015 between Iran, the P5+1 (China, France, Russia, United Kingdom, United States—plus Germany) and the European Union (EU), aimed to curb Iran’s efforts to develop its nuclear program and enrich uranium.

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Posted on 14/05/2018

Category 5 Part 2 updates - Changes to the controls on ‘Information security’ products

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The information security section of the EU dual-use regulations, Category 5 Part 2, has been modified to provide a positive list of controls to improve transparency and clarity around the applicability of these controls. The previous versions of Category 5 Part 2 had applied a broad brush control to encryption items and then sought to decontrol by exception.

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Posted on 20/04/2018

U.S. Department of Justice (DOJ) – Enhanced Security Plan Sets Best Practices for Use of Cloud Services for Sensitive Data

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In December 2017 a global software company serving the telecommunications industry settled charges with the U.S. Department of Justice for violating U.S. controls on foreign access to sensitive data, including export controlled information. As part of the settlement, the company agreed to implement an Enhanced Security Plan designed to increase information security by regulating remote access to company networks and transfers of sensitive data.

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Posted on 07/03/2018

India Joins the Wassenaar Arrangement, and Other Trade Policy Updates from New Delhi

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December 2017 brought major updates to India’s trade policy, with the country’s accession to the Wassenaar Arrangement on Export Controls for Conventional Arms and Dual-Use Goods and Technologies (Wassenaar Arrangement or WA) and the government’s release of a ‘Mid-term Review of Foreign Trade Policy (FTP) in December 2017’ (‘the Review’). These changes have broad implications for exporters operating in India and deserve careful attention across compliance functions, from export controls to tax.

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Posted on 23/01/2018