The Export Control & Sanctions Watch is a comprehensive, up-to-date resource that delivers and collects the latest export control, sanctions, and AML updates. It is not just essential, but crucial for customs professionals to maintain compliance and effectively manage trade risks. The Watch is published weekly and sent to PREMIUM subscribers, showing how much we value your role in the industry.
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Israeli Freight Forwarder Pleads Guilty to Violating Export Restrictions Imposed on Russia
Joint Statement on the Second Annual Export Enforcement Five Conference
Lithuania seizes Belarus shipment of fire trucks to Zimbabwe over sanctions
EU weighs expanding sanctions on exports to Russia - Officials consider proposal to crack down on shipments to Moscow from European company subsidiaries based overseas - Financial Times
UK and Allies Impose Major Sanctions on Iran and Russia Over Alleged Missile Transfer
On 10 September, the UK, in coordination with the US and other international partners, announced significant sanctions against Iran and Russia in response to claims that Iran has supplied ballistic missiles to Russia for use in the war in Ukraine. This escalation follows repeated warnings from Western nations urging Tehran to halt these transfers.
The UK Foreign Office announcement coincided with US Secretary of State Antony Blinken’s visit to London, where he confirmed for the first time that Russia has received new ballistic missiles from Iran. In response, the UK, France, and Germany cancelled bilateral air services agreements with Iran, effectively restricting Iran Air’s operations in Europe.
In addition to the air service cancellations, the UK and US have sanctioned key Iranian and Russian individuals and organisations involved in the missile and drone supply chains. Sanctioned entities include senior Iranian military figures linked to missile development and several Russian military organisations engaged in transporting military supplies from Iran.
The sanctions are part of a broader effort to hold Iran and Russia accountable for their actions. Over 400 sanctions are in place against Iranian entities, and more than 2,000 arerelated to Russia.
Iran has strongly criticised these actions, with Foreign Ministry Spokesperson Nasser Kanaani accusing the West of economic terrorism and promising a "corresponding and proportionate" response.
More detail: UK Government
China Criticizes New US Advisory on Hong Kong
China has strongly condemned a new US advisory warning businesses of rising legal and financial risks in Hong Kong due to its closer alignment with mainland China’s national security laws. Beijing urged Washington to "exercise caution" on Hong Kong matters.
Foreign Ministry Spokesperson Mao Ning described the advisory as a baseless attack on Hong Kong’s national security laws, accusing the US of undermining the region's business environment. "The US should respect the facts, China’s sovereignty, and the rule of law in Hong Kong," Mao stated at a press conference on 9 September.
The US advisory, issued by several agencies, highlights increasing legal similarities between Hong Kong and the People’s Republic of China (PRC), raising concerns about business operations and personal freedoms. It cites explicitly laws like the 2020 National Security Law and the Safeguarding National Security Ordinance (SNS Ordinance), which criminalize activities such as "colluding with foreign forces" and handling "state secrets," potentially affecting businesses and travelers.
UN Humanitarian Exemptions Extend to UK Sanctions
Foreign Office Minister Stephen Doughty confirmed that UN humanitarian exemptions also apply to UK sanctions regimes. In a response to a parliamentary question on 6 September, he clarified that the exemptions cover the UK's seven UN sanctions regimes and twelve combined UN-UK autonomous sanctions regimes.
“Our UK sanctions regimes include provisions for humanitarian assistance, such as licensing and exceptions, either through a General Licence or for specific entities,” Doughty explained.
The exemptions are based on UN Resolution 2664, adopted in December 2022.
Read More: UK Parliament
EU Court: Notary Services Do Not Violate Russia Sanctions
The European Court of Justice (ECJ) ruled on 5 September that notary services, such as authenticating property sales, do not constitute legal advice and, therefore, do not breach Russia's sanctions. The judgment arose from a case in which a Berlin notary refused to authenticate the sale of a flat owned by a Russian-registered company to two German nationals, citing concerns about sanctions.
The ECJ clarified that notarial authentication is a public function, carried out independently and impartially on behalf of the state. "It does not provide legal advisory services or promote the interests of any party," the court explained.
The decision emphasised that tasks associated with notarial duties, such as managing purchase price transfers and registering ownership changes, do not involve providing legal advice and are not covered by sanctions prohibiting legal services to Russian entities. Similarly, interpreters involved in the process are also exempt from the legal advisory restrictions.
Read More: European Court of Justice
UK Labour Peer Urges Secondary Sanctions on China for Supporting Russia
In a debate on Ukraine in the House of Lords on 3 September, Labour Party peer Alan West called for secondary sanctions on China, highlighting its economic support for Russia. "Russia’s continued resilience is largely due to China’s backing," West argued, noting that secondary sanctions could significantly impact China due to its reliance on imports.
West pressed junior Foreign Office Minister Jenny Chapman on whether the UK is considering these sanctions to disrupt financial flows between China and Russia. Chapman responded by emphasising the UK's efforts to target Russia’s shadow fleet of tankers, with 15 ships sanctioned for evading international sanctions.
The United States has accused China of providing dual-use goods to Russia, though Beijing insists it is engaging in "normal trade" and has warned against interference.
EU Court Allows Full Confiscation of Proceeds in Military Brokering Case
The Court of Justice of the European Union (CJEU) has ruled that EU sanctions prohibiting brokering services for military equipment to Russia permit the full confiscation of proceeds, even if the goods do not enter the EU. The 10 September decision reinforces the EU’s stance on sanctions linked to Russia’s actions in Ukraine.
The case involved Romanian company Neves 77 Solutions SRL, which brokered a deal for 32 Russian-made radio sets. Despite warnings in 2019 about EU sanctions, the firm received nearly €3 million from Russia's SFTE Spetstechnoexport. Romanian authorities fined Neves and confiscated the proceeds, leading the company to seek clarification from the CJEU on whether the confiscation was lawful, particularly since the goods never entered EU territory.
The CJEU ruled that sanctions apply even if military equipment does not pass through the EU, noting that otherwise, the sanctions could be easily circumvented. The court also upheld the confiscation, stating it was a proportionate measure aligned with the EU's goals of safeguarding Ukraine’s territorial integrity and independence.
More : European Court of Justice
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