On July 31, 2020, the Department of Commerce Bureau of Industry and Security (“BIS”) amended the Export Administration Regulations (“EAR”) to suspend the availability of all License Exceptions for Hong Kong that provide differential treatment relative to mainland China. Our blog post on prior steps taken to revoke preferential treatment for Hong Kong, including the initial announcement of these suspensions, is available here. The following partial or full License Exceptions are no longer available for…
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…
On 20 July 2020, the UK Foreign Secretary, Dominic Raab, announced that the UK will extend to Hong Kong an EU arms embargo that has applied to mainland China since 1989 (the “Arms Embargo”). This extension forms part of the UK Government’s response to the new Hong Kong National Security Law, and the increasing role that the UK Government claims China is exerting over law enforcement in Hong Kong. The Arms Embargo prohibits the export…