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Irene Esteve (Spain)

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Spain’s Export Controls Regime: Recent Developments and What Comes Next

By and 4 Mins Read

Spain’s Secretaría General de Comercio (General Secretariat for Trade) recently held an informational briefing outlining significant developments in the country’s export control framework. The session addressed both recently implemented measures and upcoming regulatory changes that are expected to reshape the way companies engage with the Spanish licensing system. The briefing also addressed a number of practical issues of relevance to operators, including the treatment of technology transfers in cloud environments and the handling of re-export obligations,…

EU Commission clarifies relationship between Incoterms and sanctions compliance in new factsheet

By , , and 3 Mins Read

The EU Commission has issued a factsheet shedding light on the relationship between Incoterms and EU sanctions compliance. It makes clear that the Incoterms “Ex Works” rule—which shifts responsibility and risk to the importer/buyer from the moment of collecting the goods—does not exempt EU-based exporters or sellers from their legal obligations under EU sanctions law. The Commission underscores that adherence to EU sanctions is mandatory for all individuals and entities under EU jurisdiction, regardless of…

Spain Approves Draft Bill Transposing EU Directive on the Criminalization of Sanctions Violations

By , , and 5 Mins Read

On March 25, 2025, the Spanish Council of Ministers approved a draft bill to implement Directive (EU) 2024/1226 on the definition of criminal offenses and penalties for the violation of Union restrictive measures and amending Directive (EU) 2018/1673 (“Draft Bill” and “Directive”, respectively). The Directive established minimum Member State requirements concerning the definition of criminal offenses and penalties for the violation and circumvention of EU sanctions. For further detail on the Directive, see our blog post…

EU Partially Suspends Sanctions Targeting Syria 

By , , and 4 Mins Read

As anticipated in its press release, the EU yesterday published in the Official Journal the first legal instruments underpinning its decision to progressively suspend its sanctions against Syria: Decision 2025/406/CFSP, Council Regulation 2025/407 and Council Implementing Regulation 2025/408. The measures include the suspension of a significant number of sanctions which have been in place for over a decade, most recently contained within Council Regulation 36/2012, as summarised below. Companies considering business in Syria previously restricted…

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