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Andrew Rose

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On 19 July, the UK Office of Financial Sanctions Implementation (“OFSI”) issued a general licence (available here) that permits payments by UK air carriers and aircraft operators to Belarus’ air traffic control service Belaeronavigatsia, an entity designated under the UK’s sanctions against Belarus.  The licence permits payments to Belaeronavigatsia for air traffic services provided pursuant to an emergency situation (being a situation requiring an aircraft to land in or overfly Belarus to avoid endangering the…

Following coordinated designations of certain Belarusian individuals and entities earlier this week (see our previous post here), the EU has announced that further sector-based economic sanctions will come into force on 25 June 2021. The restrictions are implemented by Council Regulation (EU) 2021/1030 (the “Regulation”), which amends Regulation (EC) No 765/2006. The new sanctions target a broad range of technology and software, dual-use goods and technology, tobacco, petroleum and potash products, and financial services. The…

On 11 June 2021, the Recast Dual-Use Regulation was published in the Official Journal of the European Union as Regulation 2021/821 (the “Regulation”). The Regulation, which comes into force on 9 September 2021, will replace the current Dual-Use Regulation introduced in 2009. Key changes include: Two new general export authorisations: The Regulation introduces a general export authorisation for intra-group transfers of dual use software and technology to specified countries for product development purposes, that is…

On 12 May, Advocate General (“A-G”) Hogan issued an Opinion in a case before the Court of Justice of the European Union (“CJEU”) concerning the application of the EU Blocking Statute (Regulation (EC) No 2271/96). While the Opinion is not binding on the CJEU, it signals that the EU and Member State courts are likely to take a strict approach in their interpretation of the Blocking Regulation, and highlights the complexities that face European businesses…