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Export Controls

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On 9 April 2026, the UK Office of Trade Sanctions Implementation (OTSI) announced that, from 27 April 2026, it will assume responsibility for licensing the export of sanctioned goods (and associated ancillary services) to sanctioned destinations (see here). Such licence applications will continue to be made and processed via the Department for Business and Trade’s (DBT) SPIRE system. The change will add to OTSI’s existing responsibilities for licensing sanctioned standalone services (for example professional business…

On 15 January 2026, the EU applied its new automatic and dynamic adjustment mechanism to the Oil Price Cap (“OPC”) on seaborne Russian crude oil, reducing the cap from USD 47.60 to USD 44.10 per barrel, effective 1 February 2026. The mechanism ensures that the OPC remains 15% below the average Urals crude market price over a rolling 22‑week period. On the same day, the UK confirmed that it would lower its OPC to USD…

On 26 December 2023, China’s Ministry of Foreign Affairs announced new sanctions measures under the Anti-Foreign Sanctions Law against the following parties for their involvement in the imposition of US restrictive measures on Chinese entities over their links to alleged human rights abuses in the Xinjiang Uygur Autonomous Region: The sanctioned parties are prohibited from entering China (including mainland and the Hong Kong and Macao Special Administrative regions). In addition, all properties (including movable and…

On 19 July, the UK Office of Financial Sanctions Implementation (“OFSI”) issued a general licence (available here) that permits payments by UK air carriers and aircraft operators to Belarus’ air traffic control service Belaeronavigatsia, an entity designated under the UK’s sanctions against Belarus.  The licence permits payments to Belaeronavigatsia for air traffic services provided pursuant to an emergency situation (being a situation requiring an aircraft to land in or overfly Belarus to avoid endangering the…