On 23 April 2025, the UK government published the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025, which took effect on 24 April 2025. These new regulations amended the Russia (Sanctions) (EU Exit) Regulations 2019 to introduce additional trade restrictions, focusing on export and import prohibitions, technology, and software transfers. We have set out summaries of the key new measures below. Sectoral Software The amending regulations introduce prohibitions on making available and transferring “sectoral software” to…
The Council has adopted a new decision on arms-related export controls, emphasizing the importance of responsible arms trade policies, cooperation and convergence among Member States, and the prevention of diversion to unauthorized users. On 14 April, the Council concluded its review of the EU framework for arms export control by adopting a decision (15 April 2025)[1] amending the Council’s Common Position 2008/944/CFSP, defining common rules governing the control of exports of military technology and equipment,…
On 2 April 2025, the Swiss Federal Council announced an update to the Swiss dual-use goods control lists. This change represents a noteworthy departure from the international export control regimes that have traditionally consensually updated these lists but that are currently blocked due to ongoing geopolitical tensions. As a result, Switzerland has now issued revised lists in line with key trade partners. Dual-use goods are goods that can be used for both civilian and military…
On 7 April 2025, the Dutch government announced changes to certain general licenses for transfers of dual-use and military items, as follows: These changes will be effective from 8 April 2025. Therefore, operators can no longer rely on these general licenses for transfers that are no longer covered by the respective general licenses because of the above changes. Instead, operators will need to confirm whether another general license is available (requiring a one-off prior registration…