On Thursday 6 January 2022, the European Commission published Delegated Regulation (EU) 2022/1, updating the list of dual-use items contained in Annex I to Regulation (EU) 2021/821 (the “EU Dual Use List”). Regulation (EU) 2021/821, which was published in June last year and came into effect on 9 September last year, introduced key changes to modernise the EU export controls regime for dual use items. Please see our previous post for an overview of changes,…
Earlier in December 2021, the UK Government announced a package of new measures with the aim of updating the export control regime in the UK. In particular, this includes the following aspects: i. New Strategic Export Licensing Criteria A revised version of the licensing criteria for strategic export controls has been laid before Parliament (known as the Strategic Export Licensing Criteria). This will be applied with immediate effect, and will impact all licensing decisions as…
Following recent events in Afghanistan, on 18 August 2021 the ECJU announced that open general export licences in five categories, including dual-use items, may no longer be used where the permitted destination is Afghanistan. These are: OGEL (export after exhibition: dual-use items)OGEL (export for repair/replacement under warranty: dual-use items) from December 2019OGEL (export for repair/replacement under warranty: dual-use items)OGEL (X) – from December 2019OGEL (X) Any export of military or dual-use items to Afghanistan will…
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…