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Sunny Mann

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The UK Foreign Office has indicated that it is preparing to introduce a new targeted sanctions regime immediately after Brexit. The new sanctions regime will enable the UK to freeze the assets of foreign citizens deemed responsible for human rights abuses. It will then be followed by a list of people whose assets will be frozen. The US and Canada already have such arrangements and the EU has indicated that it intends to adopt a…

On 31 December 2019, the updated Annex I (the “Dual-Use List”) to Regulation 428/2009 (the “Dual-Use Regulation”) came into effect. The changes to the Dual-Use List reflect updates to the international non-proliferation agreements during 2018, the majority of which arose from amendments to the Wassenaar Arrangement agreed in December 2019. More detailed summaries of the changes can be found in our previous updates here and here. The UK has adopted this updated list and today…

The Iranian government announced on Sunday evening that it will no longer adhere to certain limits agreed under the Joint Comprehensive Plan of Action (“JCPOA”) and will therefore no longer observe limitations on uranium enrichment, stockpiles of enriched uranium or nuclear research and development. Despite this, Iran has stated that it remains open to negotiations with partners in Europe who have sought to help Iran continue trading overseas despite US sanctions (through the INSTEX vehicle,…

On 30 December 2019, the updated Annex I (the “Dual-Use List”) to Regulation 428/2009 (the “Dual-Use Regulation”) was published in the Official Journal of the European Union (see here). The updated Regulation came into effect on 31 December 2019. The changes to the Dual-Use List reflect updates to the international non-proliferation agreements during the previous year. The majority of the changes result from amendments agreed to the Wassenaar Arrangement including: a new decontrol note for…