On 31 December 2020, the UK’s Brexit transition period with the EU ended, and the UK became a third country with respect to the EU from a sanctions and export controls perspective. The UK now has its own autonomous sanctions and export control regimes – closely related to the EU’s regimes, but with important differences and complexities that clients need to be aware of. We have written an alert that summarises the key considerations for companies in…
On December 23, 2020, the Commerce Department’s Bureau of Industry and Security (“BIS”) amended the Export Administration Regulations (“EAR”), in further implementation of Executive Order 13936 (“EO 13936”), to remove provisions that provide differential and preferential treatment for exports, reexports, and transfers of items to Hong Kong as compared to China. As a result of these changes, Hong Kong will be removed as a separate destination on the Commerce Country Chart and in other places…
The Department for International Trade has revealed in a notice to exporters that HMRC has received settlements totalling £700,368.01 for export control violations between March and September 2020.Fines of up to £211,250 were issued to exporters across 19 settlement actions for unlicensed exports of dual use goods, military goods and related activity controlled by the Export Control Order 2008. This is the highest annual total for export control fines to date.HMRC has a discretionary power…
On 16 October 2020, the Export Control Joint Unit (ECJU) published Notice to Exporters 2020/14 to remind relevant exporters to sign up for the EU dual-use open general export licence (OGEL) before the end of the Brexit Transition Period. This OGEL will be required to export dual-use items from the UK to any EU Member State and the Channel Islands from 1 January 2021. It is not required to export dual-use items to the EU…