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…
Background The European Union continues to expand its sanctions regime against Russia and Belarus. The latest – the 18th – EU Russia/Belarus sanctions package was published on 19 July 2025, and included a range of additional sanctions, mainly targeting the Russian energy, banking and military industries, but also individuals and the Russian shadow fleet (see our previous blog post on the 18th sanctions package). EU sanctions against Russia are enacted in the form of regulations,…