On 4 March 2022, the European Commission announced the introduction of the EU Sanctions Whistleblower Tool. According to the Commission, the Tool can be used to report on “past, ongoing or planned” EU sanctions violations, as well as attempts to circumvent these. Reports to the Commission can be made either directly by email or on an anonymous basis via the online platform provided through the Tool. Submitted reports will, in the first instance, be examined…
On 15 October 2021, the Dutch Minister of Foreign Affairs announced that the Dutch government has revised its licensing policy for exports of military-related items to Turkey. This policy covers both military items within the meaning of the EU Common Military List and dual-use items in case of a military end-use. The changes were announced in a letter to Dutch Parliament (available here, in Dutch). The revised policy relaxes the very strict policy that has…
Following the entry into force of the new EU Dual-Use Regulation 2021/821 last month (see also our recent post), the EU has introduced new document codes that need to be used on EU customs export declarations for exports and transits of dual-use items. Notably, specific codes now apply depending on the relevant (type of) authorisation/licence. The old code “X002” (which was previously valid for all dual-use authorisations) has been replaced and cannot be used anymore.…
In a judgement of 7 April 2020 (ECLI:NL:HR:2020:623), the Dutch Supreme Court confirmed that the EU Blocking Regulation (“EUBR”) does not prevent extradition of an Iranian national to the United States for their alleged involvement in US export controls and sanctions violations. With this judgement, the Supreme Court upheld the judgement of the District Court of Rotterdam of 5 July 2019 (ECLI:NL:RBROT:2019:5338). This case was triggered by an extradition request for an Iranian national…