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Julian Godfray (UK)

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As we wrap up our series about sanctions investigations with this post, our Global Sanctions Investigation Group has blogged about key issues that companies should keep in mind as they tackle global sanctions investigations that are inherently high-risk matters. But do you need to passively wait around for the sanctions enforcement storm to batter your company and its trade compliance team? The simple answer is a resounding no. Companies worried about sanctions compliance and potential…

On 30 September 2024, the UK Government issued a notice stating that from 31 October 2024, the provision of intra-group services will no longer be a specific licensing ground available in relation to professional and business services provided by UK companies to their Russian subsidiaries. Licence applications submitted before 31 October 2024 will not be affected by the change. Under Regulation 54C of The Russia (Sanctions) (EU Exit) Regulations 2019 (ā€œUK Russia Regulationsā€), it is prohibited…

On September 5, 2024, the European Commission published a Delegated Regulation, updating the list of dual-use items contained in Annex I to Regulation (EU) 2021/821 (the “EU Dual Use List”) The EU Dual Use List is updated annually, to ensure it remains aligned with multilateral export control regimes, including the Wassenaar Arrangement, the Missile Technology Control Regime, the Nuclear Suppliers Group and the Australia Group. The Delegated Regulation will only take effect the day after…

On 10 and 11 September 2024, the US, UK and France and Germany took coordinated action in response to Iran’s support for Russia’s war effort and, in particular, the supply of ballistic missiles by Iran to Russia for use in Ukraine. The measures announced include restrictions on Iran’s national airline, Iran Air, travel bans and asset freezes on Iranian individuals and organisations involved in ballistic missile and drone supply chains, and new Russian shipping sector…