The Export Controls & Sanction Manager - Edition 3
- Arne Mielken
- Jan 23, 2024
- 20 min read
Edition 3 - 2024 - Week 3 of your blog-style magazine on export controls & sanctions.
The period covered 16.01 - 22.01.2024.
A word from the editor
Team Export Controls and Sanctions,
The EU has finalised a deal with the Council on new measures to beef up an EU toolkit to fight money laundering, terrorist financing and sanctions evasion. Parliament and Council negotiators reached a provisional agreement on the sixth Anti-Money Laundering (AML) directive and the EU “single rulebook” regulation. The agreed provisions, part of the Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) package will have to be applied by banks and other obliged entities to protect the EU internal market from money laundering and terrorist financing. The new laws give Financial Intelligence Units (FIUs) more power to investigate and identify money laundering and terrorist financing, as well as to halt suspicious transactions.
Noteworthy this week, the EU also established a dedicated sanctions framework against Hamas and Palestinian Islamic Jihad and listed six individuals under Hamas and the Palestinian Islamic Jihad (PIJ) Sanctions. We explore this in this edition.
The U.S and the UK have imposed new sanctions on key figures in the financial networks of Hamas and Palestinian Islamic Jihad (PIJ) - key figures in the financial networks of Hamas and Palestinian Islamic Jihad (PIJ), including Zuheir Shamlakh, a key Hamas financier who has used his money exchange and cryptocurrencies to move Iranian funding to terrorist groups.
In an attempt to tighten UK export controls, the UK removed Burkina Faso, Haiti, Mali, and Niger as permissible destinations from certain OGLs and updated 13 open general licences (OGLs) to remove these as permissible destinations.
Have a captivating lecture! Any questions? Any feedback? Please feel free to reach out to us at info@customsmanager.org via email.
Arne
Content
Due Diligence & AML
U.S. Export Controls
EU Export Controls
UK Export Controls
Sanctions Updates
EU Sanctions
UK Sanctions
U.S. Sanctions
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Due Diligence & AML
For all updates, see: https://www.customsmanager.info/all-news/categories/due-diligence
Anti-money laundering: Council and Parliament strike deal on stricter rules
The Council and Parliament found a provisional agreement on parts of the anti-money laundering package that aims to protect EU citizens and the EU's financial system against money laundering and terrorist financing. With the new package, all rules applying to the private sector will be transferred to a new regulation, while the directive will deal with the organisation of institutional AML/CFT systems at the national level in the member states
The provisional agreement on an anti-money laundering regulation will, for the first time, exhaustively harmonise rules throughout the EU, closing possible loopholes used by criminals to launder illicit proceeds or finance terrorist activities through the financial system.
The agreement on the directive will improve the organisation of national anti-money laundering systems.
Deal on a single rulebook against money laundering and terrorist financing
On Thursday, MEPs finalised a deal with the Council on new measures to beef up an EU toolkit to fight money laundering, terrorist financing and sanctions evasion.
Parliament and Council negotiators reached a provisional agreement on the sixth Anti-Money Laundering (AML) directive and the EU “single rulebook” regulation. The agreed provisions, part of the Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) package, will have to be applied by banks and other obliged entities to protect the EU internal market from money laundering and terrorist financing. The new laws give Financial Intelligence Units (FIUs) more power to investigate and identify money laundering and terrorist financing, as well as to halt suspicious transactions. During the negotiations, MEPs agreed that professional football clubs must verify their customers' identities, monitor transactions, and report any suspicious transactions to FIUs starting in 2029. They also increased vigilance around ultra-rich people. The agreement includes a restriction on large cash payments of more than 10,000 euros on a European level, as well as measures to ensure that certain financial sanctions are followed and sanctions are avoided. More information on the agreement on the sixth Anti-Money Laundering (AML) directive can be found here and on Anti-Money Laundering (AML) regulation, here. The deal needs to be formally adopted by Parliament and Council before it can come into force.
Commission welcomes political agreement on the first Anti-Money Laundering Regulation and new Anti-Money Laundering Directive
The Commission applauds the European Parliament and Council's agreement on the Commission's first anti-money laundering and combating terrorism (AML/CFT) regulation and sixth directive. These ideas provide a unified AML/CFT regulation and facilitate the future Anti-Money Laundering Authority's work. The new regulations oblige the private sector to do Single Market inspections uniformly throughout the EU. To facilitate cross-border collaboration, they unify national supervisor and Financial Intelligence Unit (FIU) duties. This framework also strengthens beneficial ownership registries to enhance transparency of legal persons and trusts' owners. It also harmonises access to this information, allowing media and civic society to combat financial crime. Access to real estate information will also assist police combat illicit usage of such assets. The July 2021 AML legislation package contained several Commission suggestions, a new Regulation creating an AML/CFT Authority (AMLA), and a revised Regulation on money and crypto-asset transfer traceability. The four package ideas have been approved by co-legislators.
Export Controls Updates
To make sure you never miss an export control update, bookmark https://www.customsmanager.info/all-news/categories/export-controls
⇒ EU Export Controls
2024 EU Dual-Use Control List
Updated Common Military List of the European Union published
Commission Delegated Directive (EU) 2024/242 updating of the list of defence-related products in line with the updated Common Military List of the European Union of 20 February 2023
Supporting Ukraine's efforts to combat illicit trafficking in weapons, ammunition and explosives.
Council Decision (CFSP) 2024/330 of 16 January 2024 in support of Ukraine’s efforts to combat illicit trafficking in weapons, ammunition and explosives.
Biological and Toxin Weapons Convention
Council Decision (CFSP) 2024/349 of 16 January 2024 in support of the Biological and Toxin Weapons Convention
⇒ UK Export Controls
UK ECJU removes Burkina Faso, Haiti, Mali, and Niger as permissible destinations from certain OGLs
The UK Export Control Joint Unit has updated 13 open general licences (OGLs) to remove Burkina Faso, Haiti, Mali, and Niger as permissible destinations:
Burkina Faso, Haiti, Mali, and Niger
OGLs, where Burkina Faso, Haiti, Mali, and Niger have been removed as permissible destinations, are:
Haiti
OGLs where Haiti has been removed as a permitted destination are:
Burkina Faso, Mali, and Niger
OGLs, where Burkina Faso, Mali, and Niger have been removed as permissible destinations, are:
⇒ U.S Export Controls
Summary of the Opening Remarks by Assistant Secretary of Commerce for Export Administration Thea Kendler to the 2022 Massachusetts Export Expo
Paula Murphy, Assistant Secretary of Commerce for Export Administration, describes her work as BIS's Export Administration chief. Murphy has over 20 years of export controls expertise, dismantling procurement networks, countering intelligence threats, discouraging economic espionage, and prosecuting export control violators.
Presenting Assistant Secretary of Commerce for Export Administration
The speaker is a national security lawyer with 20+ years of expertise in export controls, including serving in the Justice Department's National Security Division's Counterintelligence and Export Control Section. With criminals trying to steal U.S. technology, export curbs have worked.
Paula Murphy was part of a team that accused Huawei with criminal activity, trade secret theft, and global financial institution fraud.
A Russian man reportedly established up a firm in Bulgaria to acquire U.S. electrical components for repackaging and shipping to Russia.
The speaker stresses the necessity of export restrictions in achieving national security, foreign policy, and economic security objectives via the EAR.
Paula Murphy clearly sees their surroundings and takes export control carefully and wisely.
Problems with national security and prosperity
Paula Murphy recognises the connection between national security, foreign policy, and economy, with authoritarian governments and non-state entities exploiting economic growth.
She trusts the Bureau of International Security (BIS) to improve America's national security, foreign policy, economic competitiveness, and technical leadership via export control regulations.
BIS's Economic Impact
BIS links significant diplomatic and military policy debates to American citizens and companies.
The agency considers national security when it affects national strength and health.
BIS evaluates goods, engineering, worldwide threat, market, R&D financing, international availability, and more.
BIS Non-Proliferation Concerns
BIS must adapt to shifting conditions and identify transaction-related businesses, the speaker says.
The agency may act rapidly and independently, as seen in the 0Y521 ECCNs for geospatial imaging analysis software.
US National Security and Technology Cooperation
The US government values research, innovation, and international cooperation for national security.
The US government encourages U.S. corporations to join international standards organisations to boost the economy and global security.
All stakeholders must battle threats to ensure national security, according to the speaker.
Since private sector partners are the front lines of national security, the speaker stresses continuous interaction with them.
Collaboration priorities include export regulations to prevent technical innovation from being used for national security damage.
Export limits should be tailored to minimise disincentivizing technical leadership and restore resources to the U.S. for innovation and research.
The speaker supports multilateral export restrictions and urges partner nations to recognise national security considerations and impose controls equally.
Appreciate BIS's analytical capacity for export controls, understanding industry, and fostering innovation.
Highlight the significance of semiconductors and BIS's role in identifying national security threats.
February 27-March 1, 2024 Complying with U.S. Export Controls seminar, Live Online
In partnership with the World Trade Center Denver, and utilizing the power of virtual, interactive learning tools, BIS is offering our popular Complying with U.S. Export Controls seminar as an online program. This interactive course delivers critical information for compliance with the Export Administration Regulations (EAR). Here are details
March 27-29, 2024, Update Conference on Export Controls and Policy, Washington, D.C.
BIS has rescheduled the Update Conference on Export Controls and Policy to March 27-29, 2024. Details
April 9-10, 2024, Complying with U.S. Export Controls seminar, St. Louis, Missouri
In partnership with the Missouri District Export Council, BIS is offering a two-day in-person program that will cover the information exporters need to know to comply with U.S. export control requirements under the Export Administration Regulations. Click here for details.
Sanctions Updates
The EU, UK and US implement extensive sanctions laws. These rules provide processes for producing lists of individuals and businesses subject to asset freeze targets and financial and investment restrictions. Businesses must stay up to date with the latest sanctions rules to avoid accidental non-compliance. Read the collection of all articles we have written on this topic here https://www.customsmanager.info/all-news/categories/sanctions
⇒ EU Sanctions Updates
Hamas and Palestinian Islamic Jihad: Council establishes dedicated sanctions framework
The European Union has established a dedicated sanctions framework against Hamas and the Palestinian Islamic Jihad (PIJ), aiming to hold accountable individuals or entities who support, facilitate, or enable violent actions by these groups. The decision was made in response to recent attacks against Israel and the need to fight against violent actions that threaten peace and international security. The new regime complements the restrictive measures previously adopted against Hamas and the PIJ under Common Position 2001/931/CFSP (the ‘EU terrorist list’). The EU may target those who support, materially or financially, Hamas or the PIJ, or those who participate in the planning, preparation, or enabling of violent actions by Hamas or the PIJ. The new sanctions regime will apply until 19 January 2025 and will be kept under constant review and renewed or amended as appropriate if the Council deems its objectives have not been met.
EU lists six individuals under Hamas and the Palestinian Islamic Jihad (PIJ) Sanctions
Today, the Council also decided to list six individuals of different nationalities responsible for providing financial support to Hamas. Included are Sudan-based financier Abdelbasit Hamza Elhassan Mohamed Khair, owner of 'Shuman for Currency Exchange SARL' Nabil Chouman, the former's son Khaled Chouman, senior Hamas financier Rida Ali Khamis, senior Hamas operative Musa Dudin and Algeria-based financier Aiman Ahmad Al Duwaik.
Those listed under the sanctions regime are subject to an asset freeze. The provision of funds or economic resources, directly or indirectly, to them or for their benefit is prohibited. Additionally, a travel ban to the EU applies to the natural persons listed.
The new sanctions framework shall apply until 19 January 2025. It shall be kept under constant review and renewed or amended as appropriate, if the Council deems that its objectives have not been met.
EU Sanctions Against ISIL(Da'esh) and Al-Qaida
Fight against terrorism: Council adds an individual to its autonomous sanctions list against ISIL(Da'esh) and Al-Qaida - See Council Implementing Regulation (EU) 2024/338 & Council Decision (CFSP) 2024/333. Commission Implementing Regulation (EU) 2024/372 of 17 January 2024 amending for the 341st time Council Regulation (EC) No 881/2002 imposing certain specific restrictive measures directed against certain persons and entities associated with the ISIL (Da'esh) and Al-Qaida organisations.
EU Sanctions Against Terrorism
The EU sanctioned Gaza's Hamas commander, Yahya Sinwar, on Tuesday for the group's October 7 assault on Israel. Both sources stated this move was done within the current sanctions framework and is different from the measures EU foreign ministers would declare on Monday. In recent months, the U.S. and Israel have pressured European politicians to penalise Hamas officials and “financial facilitators” in Sudan, Turkey, Algeria, and Qatar.
Human Rights In China
The European Parliament adopted three resolutions on human rights issues in China, Sudan and Tajikistan
Europan Court
⇒ UK Sanctions Updates
The UK has imposed new sanctions on key figures in the financial networks of Hamas and Palestinian Islamic Jihad (PIJ)
The UK has imposed new sanctions on key figures in the financial networks of Hamas and Palestinian Islamic Jihad (PIJ), including Zuheir Shamlakh, a key Hamas financier who has used his money exchange and cryptocurrencies to move Iranian funding to terrorist groups. This is the third round of sanctions imposed on Hamas and PIJ following the 7 October attacks on Israel.
The UK is committed to working with partners to tackle Iran's destabilizing activities in the Middle East, including its long-term support to terrorist and militant groups. The individuals now subject to UK asset freezes and targeted arms embargoes include Shamlakh, Ahmed Sharif Abdallah Odeh, Ismail Barhoum, Hassan Al-Wardian, and Jamil Yusuf Ahmad Aliyan. They are also subject to a travel ban and will be unable to enter the UK.
This is the third tranche of sanctions the UK has imposed against Hamas and its associates since 7 October under the UK’s International Counter-Terrorism sanctions regime. The Foreign Secretary continues to work with allies and partners to find a peaceful resolution to this conflict.
6 entries added to the consolidated list: Hamas and Palestinian Islamic Jihad (PIJ)
On 22 January 2024 the Foreign, Commonwealth and Development Office updated the UK Sanctions List on GOV.UK. This list provides details of those designated under regulations made under the Sanctions Act.
The following 6 entries have been added to the Counter-Terrorism (International) financial sanctions regime and are now subject to an asset freeze:
Jamil Yusuf Ahmad Aliyan (Group ID: 16341)
Hassan Al-Wardian (Group ID: 16339)
Ismail Barhoum (Group ID: 16340)
Ahmed Sharif Abdallah Odeh (Group ID: 16342)
Zuheir Shamlakh (Group ID: 16343)
Al Mutahadun For Exchange (Group ID: 16344)
OFSI’s consolidated list of asset freeze targets has been updated to reflect these changes.
OFSI upcoming webinars
OFSI has published details of its upcoming webinars and events:
15 February 2024: “Understanding Licensing for UK Financial Sanctions”;
29 February 2024: “UK Financial Sanctions and the Maritime Sector”.
Sign up for email alerts to receive notifications about these events here.
UK revises general licence for Russian vessels
On January 18, 2024, the UK revoked and replaced General Trade Licence Russia Sanctions – Vessels. Per Notice NTE 2024/02, the General Licence has been revised to include with its scope regulations relating to the import, supply and delivery of Schedule 3DA revenue generating goods as well as related services. (General Trade Licence Russia Sanctions - Vessels (publishing.service.gov.uk)).
UK Government amends one entry on the UK sanctions list under the Russian regime
On January 15, 2024, the UK Government amended one entry on the Russia sanctions list relating to Svyatoslav Evgenievich Ostrovsky. This individual remains subject to an asset freeze and trust services sanctions.
UK court rejects Graham Phillips’ Sanctions Act challenge
A case concerning Graham Phillips, who was sanctioned by the UK in July 2022 for creating propaganda films endorsing Russia's invasion of Ukraine, has been decided by the Administrative Court in England. Phillips contested the ruling, claiming that the UK government lacked the authority to punish people for their political beliefs. Nonetheless, the court determined that Phillips' video material supported the Russian invasion of Ukraine and that the UK government had the authority to impose penalties on anybody who encouraged or supported actions that destabilised Ukraine or threatened its independence and sovereignty. It was decided that Phillips' pecuniary penalties were appropriate. (Graham William Phillips v The Secretary of State for Foreign, Commonwealth and Development Affairs - Find case law - The National Archives).
UK Government amends one entry on the UK sanctions list under the Belarus regime
The UK Government amended one entry on the Belarus sanctions list relating to Petr Aleksandrovich Orlov. This individual remains subject to an asset freeze.
UK Government amends four entries on the UK sanctions list under ISIL (Da'esh) and Al-Qaeda regime
On January 15, 2024, the UK Government made administrative amendments to four entries under the Isil (Da'esh) and Al-Qaeda sanctions regime. The amended entries were in respect of: (i) Tayeb Nail; (ii) Saifi Ammar; (iii) Said Arif; and (iv) Habib Ben Ahmed Al-Loubiri. These individuals remain subject to an asset freeze, arms embargo, and travel ban.
The UK's Consolidated Sanctions' List
Access the latest version of the UK consolidated sanctions list now. Date of last update 23.01.2023. Access here
UK Financial sanctions targets by regime
Exploring the Latest UK Financial Sanctions Targets Across Different Regimes. Full List of all Regimes
⇒ U.S. Sanctions Updates
U.S. Target Additional Hamas Financial Networks and Facilitators of Virtual Currency Transfers
The U.S. imposed a fifth round of sanctions on Hamas since the October 7 terrorist attack on Israel. Today’s action targets networks of Hamas-affiliated financial exchanges in Gaza, their owners, and associates, and particularly financial facilitators that have played key roles in funds transfers, including cryptocurrency transfers, from the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) to Hamas and Palestinian Islamic Jihad (PIJ) in Gaza.
Treasury Targets Kata’ib Hizballah Leaders and Airline Enabling IRGC-QF and Militant Proxy Groups
The US has designated Iraqi airline Fly Baghdad and its CEO for aiding the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and its proxy groups in Iraq, Syria, and Lebanon. The OFAC is also designating three leaders and supporters of Kata’ib Hizballah (KH), a key Iran-aligned militia in Iraq, and a business that moves and launders funds for KH. This action highlights the ongoing threat IRGC-QF and its proxy network pose to US personnel and the region, as KH has carried out escalating drone and missile attacks against US personnel in Iraq and Syria since Hamas's attack on Israel.
General Licence 27 Updates
The Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing Counter Terrorism General License 27, "Authorizing Civil Aviation Safety and Wind Down Transactions Involving Fly Baghdad."
Counter Terrorism Frequently Asked Question
OFAC is also issuing one new Counter Terrorism Frequently Asked Question (1159).
OFAC publishes a video tutorial on how to use the sanctions list search tool
Treasury Targets Price Cap Violation-Linked Shipping Company
The U.S is taking its first oil price cap enforcement action of 2024, targeting a shipping company linked to a price cap violation. United Arab Emirates-based shipping company Hennesea Holdings Limited (Hennesea) is the ultimate owner of 18 vessels, including the HS Atlantica, which OFAC previously identified as having engaged in the transport of crude oil of Russian Federation origin priced above the $60 per barrel price cap while using a covered U.S.-based provider after the price cap policy came into effect. On December 1, 2023, OFAC identified the HS Atlantica as property in which Hennesea’s subsidiary, U.S.-designated HS Atlantica Limited, has an interest. Today, OFAC is additionally re-identifying the HS Atlantica as property in which Hennesea has an interest. Shortly before the price cap went into effect, Hennesea, which was established in late 2022, acquired older tankers that ship Russian crude oil and petroleum products. Tankers ultimately owned by Hennesea have repeatedly conducted port calls in Russian Federation ports. Hennesea was designated pursuant to E.O. 14024 for operating or having operated in the marine sector of the Russian Federation economy.
OFAC identified the following vessels, all of which are beneficially owned by Hennesea, as property in which Hennesea has an interest:
ARISTO (IMO 9327413)
HAI II (IMO 9259599)
HS ARGE (IMO 9299745)
HS ATLANTICA (IMO 9322839)
HS BURAQ (IMO 9381732)
HS ESBERG (IMO 9410894)
HS EVERETT (IMO 9410870)
HS GLORY (IMO 9249087)
HS LEGEND (IMO 9381744)
HS STAR (IMO 9274446)
LA PRIDE (IMO 9274616)
MONA (IMO 9314818)
NELLIS (IMO 9322267)
OSPEROUS (IMO 9412995)
PERIA (IMO 9322827)
SARA II (IMO 9301615)
SENSUS (IMO 9296585)
UZE (IMO 9323338)
US terrorism General Licences and SDN list changes
OFAC has issued the following GLs:
OFAC have updated the SDN list, adding the following individual:
PIMENTEL MATA, Alberto (a.k.a. PIMENTEL, Alberto) nationality Guatemalan
and removing 9 individuals, listed here.
⇒ UN Sanctions Updates
UN modifies DPRK sanctions and terrorist lists
The UN has added further details on specific people and organisations to seven of the items on its list of sanctions against ISIL (Da'esh) and Al-Qaida. Two items on the UN's list of DPRK sanctions have been modified to provide further identifying information. Find out details here
⇒ China Sanctions Updates
China is a party to the UN and carries out its sanctions. The Anti-Foreign Sanctions Law 2021 of China stipulates that foreign entities that have implemented “discriminatory and restrictive” actions against Chinese persons or companies are subject to counter-sanctions.
China sanctions U.S. firms
As of January 8, 2024, China has designated US defence firms for selling armaments to Taiwan. Under China's Anti-Foreign Sanctions Law, the Chinese Ministry of Foreign Affairs has stated that it has sanctioned five United States defence corporations. The sanctions include the freezing of the properties of those businesses in China, as well as the prohibition of organisations and persons in China from engaging in transactions and cooperating with those companies. Alliant Techsystems Operation, BAE Systems Land and Armament, AeroVironment, and ViaSat are some of the companies that provide Data Link Solutions. These restrictions were implemented as a reaction to the United States' decision to provide weaponry to Taiwan and to impose penalties on Chinese businesses and persons. Link here
China forbids the export of technology used in the production of rare earths.
Back in April 2023, China said it would implement export limitations on technologies related to rare earth metals. In November 2023, China implemented a requirement for reporting instances of rare earths. Reportedly, now, China prohibited the export of technologies meant to be used in rare earth production. This follows China's earlier this month introduction of import and export reporting laws about rare earths. See FT report
Upcoming Export Control and Sanctions Training
Learn the essentials of dual-use products and export limits to avoid expensive fines. Our training will be advantageous to any US and non-US firm engaging in international trade, especially concerning items of US origin. Our training help prevent expensive export control and sanctions fines. It imparts essential knowledge that personnel responsible for export controls and sanctions compliance need to grasp.
Sanctions
This course develops the competencies that professionals need to deal with all key compliance aspects of sanctions laws and policies. Using examples from the EU, the UK and the U.S., we will explore how to check entities, individuals and organisations against sanctions lists, how to set up an effective restricted party screening programme, how to identify economic trade sanctions and how your products may be affected by it. We will determine due diligence requirements, and how you can identify attempts for circumvention. We will discuss how to apply for a sanction’s exemption licence, a licence exception / general licence. Includes a discussion around red flags and how to set up a sanctions policy and programme. Special feature: Participants will workshop through real sanctions’ case studies and explain the action that they would take to ensure compliance.
Dates (Click To Book)
Export Controls
This course develops the competencies that professionals need to deal with the four fundamental aspects of export controls: Product, Destination, End-User and End-Use Controls. Using examples from the EU, the UK and the U.S., we will explore how to determine if an item is subject to export controls and detail the steps to acquire an export control licence and/to apply for a licence exception / general licence. Includes a discussion around red flags and Internal Export Compliance Programmes (ICP/ECP). Special feature: A hands-on workshop where you get to determine the export control rating of your product by yourself (supported by your expert instructor).
Dates (Click To Book)
U.S. Export Controls
This course focuses on U.S. Export Controls, the EAR and ITAR. Discover how an item can be subject to the EAR or ITAR, how to verify items against the CCL or the USML, how to determine licence requirements and licence exceptions, how to make a licence application, check Export Controls specific restrictive lists and more. We cover
The enforcement authority of the Bureau of Industry and Security (BIS) extends overseas.
Key US law on export restrictions and importance for non-US firms.
Concepts and definitions related to dual-use products.
the many categories of EAR bans for non-US companies.
The many export classifications and categories, including dual use.
The Commerce Control List: An Introduction (CCL).
the primary dangers associated with doing business with US companies.
Fines and penalties.
Vigilance and warning signs.
How to create an export compliance programme (ECP) that works?
How BIS licences are applied for.
Special feature: A close look at the extraterritorial application of U.S. Export Controls – De Minimis, Foreign Direct Product Rule, Second Incorporation Principle and more
Dates (Click To Book)
What if I have a question regarding these updates
We invite you to use the chat function available on www.customsmanager.org to ask any questions related to this update. Our skilled team of export control and sanctions managers will be happy to provide you with the information you need within 24 hours.
Sources
EU
Official Journal of the EU
DG TRADE Website
Social Media (LinkedIn, Twitter, etc).
Information on the National Export Control & Sanctions Website of Member States
U.S.
Bureau of Industry and Security (BIS)
Department of Commerce
Office of Foreign Asset Control (OFAC)
Social Media (LinkedIn, Twitter, etc).
UK
Information on gov.uk
Information on legislation.gov.uk
Department of Business and Trade
Social Media (LinkedIn, Twitter, etc).
Other
United Nations (Sanctions)
Social Media (LinkedIn, Twitter, etc).
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