Sunny Mann


The Recast Dual-Use Regulation published as Regulation 2021/821 has entered into force today (9 September 2021). EU producers of dual-use goods now face new export control rules, which we have analysed in further detail in a recent post. For more detail on the Regulation, please contact Alex Phillips to receive our full client alert and analysis.

On 20 August 2021, the Foreign, Commonwealth and Development Office updated the UK Chemical Weapons financial sanctions regime to include seven Russian nationals linked to the poisoning of Alexei Navalny, the Russian opposition leader. Listed below, the individuals are subject to an freezing of assets and economic resources. Alexey Alexandrov;Vladimir Panyaev;Ivan Vladimirovich Osipov;Vladimir Mikhailovich Bogdanov;Kirill Vasilyev;Stanislav Valentinovich Makshakov;Alexei Semenovich Sedov.

Following recent events in Afghanistan, on 18 August 2021 the ECJU announced that open general export licences in five categories, including dual-use items, may no longer be used where the permitted destination is Afghanistan. These are: OGEL (export after exhibition: dual-use items)OGEL (export for repair/replacement under warranty: dual-use items) from December 2019OGEL (export for repair/replacement under warranty: dual-use items)OGEL (X) – from December 2019OGEL (X) Any export of military or dual-use items to Afghanistan will…

On 5 August 2021, the Office of Financial Sanctions Implementation (“OFSI”) imposed a GBP 50,000 penalty on TransferGo Limited (“TransferGo”), a UK FinTech company, for breaching UK sanctions when it issued instructions to make payments to accounts held at the Russian National Commercial Bank (“RNCB”), a designated party. Between 20 March 2018 and 18 December 2019, TransferGo issued instructions to make 16 payments into accounts held at RNCB, the total value of which was…