On 7 April 2025, the Dutch government announced changes to certain general licenses for transfers of dual-use and military items, as follows: These changes will be effective from 8 April 2025. Therefore, operators can no longer rely on these general licenses for transfers that are no longer covered by the respective general licenses because of the above changes. Instead, operators will need to confirm whether another general license is available (requiring a one-off prior registration…
Earlier this year, the EU introduced various new restrictions as part of its sanctions packages targeting Russia (see our blog post on the 14th EU Russia sanctions package) and Belarus (see our blog post of the most recent EU Belarus sanctions package). Among the notable and novel restrictions were: Businesses should therefore review their current practices and consider whether any enhancements are necessary to comply with these measures. Guidance on âbest effortsâ obligations The “best…
On 18 October 2024, the Dutch government announced supplemental controls for exports of certain emerging technology items from the Netherlands. These controls will enter into force on 1 December 2024 and will be implemented through the Dutch Regulations Supplemental Controls to the Dual-Use Regulation (Regeling aanvullende controlemaatregelen op de Verordening producten voor tweeĂ«rlei gebruik, the “Dutch Regulations”). The official text of the Dutch Regulations is available here. Scope of Unilaterally Controlled Items The Dutch Regulations…
As risks and complexities for sanctions investigations have grown, so has the number of regulators and enforcement agencies bringing enforcement actions, and not just in the United States. Enforcement agencies around the world are becoming more active, with a focus on enforcing sanctions and export controls targeting Russia since its February 2022 invasion of Ukraine. There has been a particular uptick in public enforcement of EU sanctions targeting Russia by various EU Member States in…