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…
Join us in Mountain View, California on Thursday, November 12, for an exclusive in-person forum on Trade Strategy in a Fragmented World.This in-person event will precede our webinar series – the 47th Year-End Review of Global Trade Developments Conference. PLEASE NOTE: This in-person session is a standalone experience and serves as a complement to the virtual conference taking place through webinars the following week between November 17-19, 2026. Each format offers distinct content and networking opportunities. The details for both events are included below. In-Person Forum→ Trade Strategy in a…
France has taken its first formal step toward implementing Directive (EU) 2024/1226, which requires all EU Member States to criminalise the violation and circumvention of EU restrictive measures. The Directive was adopted to address persistent divergences in national enforcement regimes and to ensure that breaches of EU sanctions are treated consistently as criminal offences across the European Union (EU). The Directive establishes a minimum harmonisation of offences and penalties, covering conduct such as providing funds…
On 4 December 2025, the UK Office of Trade Sanctions Implementation (“OTSI”) published a corporate report marking the first year since its launch in October 2024 (see here). Our previous blog post providing more background on OTSI’s powers and jurisdiction can be found here. The corporate report summarises OTSI’s activities during this first year, including licensing and enforcement activity, efforts to engage with businesses, collaboration with international partners and other government functions, as well as…