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Export Controls

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On October 9, 2019, the US Commerce Department’s Bureau of Industry and Security (“BIS”) added 28 Chinese entities to the Entity List because they are accused by the US Government of being associated with human rights violations and abuses against Uighurs, Kazakhs, and other members of Muslim minority groups in the Xinijiang Uighur Autonomous Region (“XUAR”). All exports, reexports, or in-country transfers of items (i.e., goods, software, technology) subject to the Export Administration Regulations (“EAR”), including EAR99 items, are now subject to a license requirement to such entities. The final rule also includes an extensive list of aliases for these entities.

The EU Council has announced its intention to modernise the current EU regime “for the control of exports, transfer, brokering, technical assistance and transit of dual-use items”. Objective of the mandate The purpose of the mandate is to reinforce the non-proliferation of weapons of mass destruction and their means of delivery, security, stability and regional peace in addition to the respect for international humanitarian law and human rights. Proposed changes A number of amendments will…

Introduction Following the recent third rejection of the Brexit withdrawal agreement in the UK Parliament, a no-deal Brexit remains firmly on the agenda. This alert sets out some of the main sanctions and export controls issues arising from a no-deal Brexit which are likely to impact upon companies operating in the UK and EU, and provides guidance on what companies can do to prepare for this eventuality. The status of EU law post no-deal Brexit…

As part of the UK government’s planning for a No Deal Brexit, the UK Department for International Trade (DIT) has published an open general export licence (“OGEL”), allowing the export of dual-use items (with both a civilian and military application) from the UK to EU Member States and the Channel Islands (full licence here). The OGEL will come into force at 11pm on 29 March 2019 if the UK leaves the EU on that date…