On 15 October 2026, the UK introduced an expanded human rights sanctions regime, via the UK’s new Global Human Rights and International Humanitarian Law Sanctions Regulations 2026 (the “2026 Regulations”). The 2026 Regulations revoke and replace the Global Human Rights Sanctions Regulations 2020 (the “2020 Regulations”). These reforms notably enable the UK to impose sanctions for serious violations of international humanitarian law, as well as for obstructions of humanitarian assistance and conduct that seriously violates…
On September 14, 2026, the EU Commission adopted a Delegated Regulation updating Annex I to Regulation (EU) 2021/821 (“EU Dual-Use Regulation”). Although the changes have not yet entered into force, the Delegated Regulation sets out the expected amendments to the EU Dual-Use Regulation. Background Annex I to the EU Dual-Use Regulation lists dual-use items that require an export authorization pursuant to Article 3(1) of the EU Dual-Use Regulation. The EU Commission periodically, usually at least…
On 25 June 2026, the UK’s Export Control Joint Unit (“ECJU”) introduced a new Open General Export Licence for dual-use items (“Dual-Use OGEL”) intended to simplify licensing requirements for UK exporters of dual-use items by providing a single, streamlined licensing process for exports to certain low-risk destinations. The Dual-Use OGEL entered into force immediately upon its publication. The Dual-Use OGEL consolidates two existing licences (the EU Member States Dual-Use OGEL and General Export Authorisation (GEA)…
We are flagging a recent example of continued coordination on sanctions between the United States, United Kingdom, and Australia focused on cybercrime. On November 19, 2025, the United States, United Kingdom, and Australia jointly imposed sanctions on Russia-based bulletproof hosting (“BPH”) service providers Media Land and ML Cloud and 2 of their key personnel after determining they had supported ransomware operations and other cybercrimes. The US OFAC announcement is here, the UK Government announcement is…