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Ben Smith

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On Monday 11 March, the UK Export Control Joint Unit (the “ECJU”) announced amendments to its Export Control Order 2008 (the “2008 Order”) and Council Regulation (EC) No 428/2009 (the “Retained Dual-Use Regulation”), pursuant to the Export Control (Amendment) Regulations 2024 (the “Regulations”). The Regulations will come into force on 1 April 2024 and will amend Schedules 2 and 3 of the 2008 Order, as well as Annex I of the Retained Dual-Use Regulation. Amendments…

On 14 December 2023, the UK Government introduced two regulations (The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 and The Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023) amending The Russia (Sanctions) (EU Exit) Regulations 2019 to impose further restrictions on goods, technology, and sources of funding that the UK Government considers could support Russia’s war against Ukraine. The majority of the amendments came into force on 15 December 2023; however a…

In recent weeks, there have been a number of noteworthy developments highlighting the increasing focus that US, EU, UK and other governments are placing on the potential circumvention of sanctions against Russia, and the roles of third countries and companies in facilitating the circumvention or undermining of such sanctions measures. These anti-circumvention efforts are taking place in the context of the G7’s concerted effort to bolster sanctions enforcement around the world, through the creation of…

The UK has announced a new package of sanctions against Russia. This will include the following sanctions: Export bans on every item Russia has been found using on the battlefield to date. Goods will include aircraft parts, radio equipment, and electronic components that can be used by the Russian military industrial complex, including in the production of UAVs. Import bans on 140 goods including iron and steel products processed in third countries. Extension of existing…