Category

Export Controls

Category

On December 22, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published a final rule (“Final Rule”) in the Federal Register adding 77 entities and individuals to the Entity List, including several prominent Chinese multinationals (together, the “Designees”). The Final Rule took effect on December 18, 2020. On the same day, BIS also published FAQs related to its recent expansion of the foreign-produced direct product rule (the “Huawei FPDP Rule”). Entity List Designations In press…

On 7 October 2020, the European Commission adopted the revised Annex I (the “Dual-Use List”) to Regulation 428/2009 (the “Dual-Use Regulation”) (see here). The new Dual-Use List came into force on 15 December 2020. The Dual-Use List is refreshed on an annual basis to take into account updates to international non-proliferation regimes and export control arrangements. The latest updates reflect changes from reviews carried out by the Wassenaar Arrangement in particular, and also from reviews…

The UK Government published a notice to exporters on 4 August 2020, stating that the Export Control Joint Unit (ECJU) has removed Hong Kong as a permitted destination from 22 open general licences, including: 20 open general export licences (OGELs);1 open general transhipment licence (OGTL); and1 open general trade control licence (OGTCL). In addition, the ECJU has revoked 2 open general licences (one OGEL and one OGTL) where Hong Kong was the only permitted destination.…

On 28 July 2020, the EU agreed to impose EU-wide measures to restrict the export of certain items to Hong Kong. The EU Council’s press release can be found here. These restricted goods include equipment or technology that could be used for internal repression, interception of internal communications or cyber surveillance. Like recent US and UK measures, the new EU export controls have been proposed in response to the recent HK National Security Law. Germany…