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Export Controls

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On June 4, 2025, the U.S. House of Representatives passed the Ukraine Support Act (H.R. 2913) (the “Act”), a broad measure that would, if enacted, (1) impose new Russia-related sanctions, (2) codify and tighten existing U.S. export controls, (3) impose duties of at least 500% on Russian imports and taxation of blocked assets, and (4) authorize additional Ukraine-related security and reconstruction measures. The bill now moves to the Senate, where its prospects remain uncertain. If…

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)…

On June 8, 2026, the US Department of Defense (“DoD”) published an update to its list of “Chinese military companies” (“CMCs”) operating directly or indirectly in the United States (the “1260H List”), pursuant to Section 1260H of the National Defense Authorization Act for Fiscal Year 2021 (the “NDAA 2021”). The updated list is available here. The DoD press release states that this update is part of the US government’s continuing effort to highlight and counter…

On 9 June 2026, European Commission President Ursula von der Leyen announced that the European Commission is preparing a 21st sanctions package against Russia, marking a further step in the EU’s ongoing effort to intensify economic pressure following Russia’s continued aggression in Ukraine. The proposed measures focus on high-impact sectors, including energy, financial services (including crypto-assets) and trade restrictions. Key Elements of the Proposed 21st Package Energy and Transport: Expanded Targeting of the Shadow Fleet…