Background On 15 January 2026, the German Parliament adopted legislation transposing Directive (EU) 2024/1226, which defines and harmonizes criminal offenses and penalties for breaches of all EU restrictive measures (i.e., sanctions). The directive’s core provision, Article 3, sets out a comprehensive list of criminal offenses that cover most types of sanction violations. Transposing the directive into national law, Germany revised key provisions in sections 18 and 19 of the Foreign Trade and Payments Act (Außenwirtschaftsgesetz(AWG))…
On 8 September 2025, the EU Commission adopted a Delegated Regulation updating Annex I of the Regulation (EU) 2021/821 (“EU Dual-Use Regulation”). Although the changes have not yet entered into force, they outline the likely amendments to the EU Dual-Use Regulation. Background Annex I of the EU Dual-Use Regulation lists dual-use items that require export authorization pursuant to Article 3 paragraph 1 EU Dual-Use Regulation. Annex I is periodically amended, usually at least once a year, based on decisions…
There have been a number of fluctuating developments in the UN and EU’s approach to Iran over the past few weeks, with a further attempt to salvage negotiations in an agreement on 10 September. We set out further details herein, including consideration of the sanctions implications. Political Developments At the end of August, amid concerns regarding Tehran’s continued resistance to international nuclear oversight and Russia’s upcoming presidency of the United Nations Security Council, the E3…
At the Annual Compliance conference recently held in London, Baker McKenzie hosted a session on ‘The evolving national security, sanctions and export controls landscape’. This session introduced the concept of the “trade toolbox” — a growing set of measures designed to manage national security risks through trade and investment restrictions. Speakers highlighted the increasing complexity of global compliance, particularly in relation to business relating to China, Russia, and in the Middle East. China: outbound investment,…