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UK Export Controls

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China’s Export Control Law (“ECL”) came into effect on 1 December 2020, providing a framework to a series of separate administrative regulations on export controls issued prior to the law’s enactment. While no implementing rules or regulations under the ECL have been enacted since its passage into law, China’s Ministry of Commerce (“MOFCOM”) recently released Announcement No. 10 of 2021, on “Internal Compliance Guidelines on the Export of Dual-Use Items” (hereafter, the “Guidelines”) pursuant to…

On 31 December 2020, the UK’s Brexit transition period with the EU ended, and the UK became a third country with respect to the EU from a sanctions and export controls perspective. The UK now has its own autonomous sanctions and export control regimes – closely related to the EU’s regimes, but with important differences and complexities that clients need to be aware of. We have written an alert that summarises the key considerations for companies in…

On December 23, 2020, the Commerce Department’s Bureau of Industry and Security (“BIS”) amended the Export Administration Regulations (“EAR”), in further implementation of Executive Order 13936 (“EO 13936”), to remove provisions that provide differential and preferential treatment for exports, reexports, and transfers of items to Hong Kong as compared to China. As a result of these changes, Hong Kong will be removed as a separate destination on the Commerce Country Chart and in other places…

The Department for International Trade has revealed in a notice to exporters that HMRC has received settlements totalling £700,368.01 for export control violations between March and September 2020.Fines of up to £211,250 were issued to exporters across 19 settlement actions for unlicensed exports of dual use goods, military goods and related activity controlled by the Export Control Order 2008. This is the highest annual total for export control fines to date.HMRC has a discretionary power…