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CBAM continues to cause concern for the iron & steel, aluminium, energy, fertilizer, hydrogen, and cement sectors one month after it went into force, with several observers saying it puts a monkey wrench in their plans. We explore what was said. The idea behind the European Union's Carbon Border Adjustment Mechanism (CBAM) is to prevent cheaper, dirtier items from undercutting EU companies that must meet stricter climate requirements and pay for pollution under the emissions trading plan. EU officials anticipate global industrial decarbonization to accelerate. The CBAM mechanism is one of five legislative actions from the Fit for 55 package, which was approved by the European Parliament in April 2023. The package aims to reduce greenhouse gas emissions by 55% by 2030 (compared to 1990 levels). With a transition period during which importers are only required to report, it goes into effect on October 1, 2023. The process will be applied gradually over the course of 2026–2034 as the ETS increasingly removes free permits. "The problems that were raised before have not been addressed, and we find ourselves in the same predicament as we were one month prior" said one of our clients, an importer of CBAM goods (on & steel, aluminium, energy, fertilizer, hydrogen, and cement goods and their products) claims that there is still a lot of ambiguity on how CBAM will affect international commerce and the supply chain. During the 2024–2026 transitional period, all iron & steel, aluminium, energy, fertilizer, hydrogen, and cement producers as well as those that process these CBAM products will be required to reveal their direct and indirect emissions. Importers have to then report it to the EU Commission, and exporters are the "middleman". CBAM: Stay informed with our extensive collection of articles, guidance documents, factsheets, and more. We provide updates on all developments related to CBAM, including information at the commodity level. You can find all the updates about the Carbon Border Adjustment Mechanism (CBAM) at the following link: https://www.customsmanager.info/all-news/categories/cbam Importers concern Many EU importers of CBAM goods are finding it difficult to submit embedded emissions, although the transitional phase offers some flexibility since it acts as a trial period and will help the EU gather all data on embedded emissions. "It is clear that the likelihood of reporting embedded emissions inaccurately is substantial. "Suppliers are not always transparent in giving full details, and checking the accuracy of information is tricky," said a European importer of CBAM goods. Reports on default settings will also stop at the end of the next year, they said. Since they will need more workers to manage the EU documents, some small importers in the UK and EU are also worried. Smaller importers find it difficult, particularly at this moment when steel is already under strain. It is simple for large importers in the UK and the EU to recruit additional workers." "The EU can provide small businesses with CBAM with more support," said Arne Mielken, CBAM consultant at Customs Manager Ltd. The first importer reporting period began on October 1 which was the commencement of the CBAM's transitioning phase. As per the European Union, the National Competent Authority (NCA) of the Member State where the importer is headquartered is the one who grants access to the transitional registration. Revolutionize Your CBAM Strategy with the Ultimate 2024 CBAM Bundle: Download Now Our fantastic bundle includes essentials for EU and non-EU CBAM importers and exporters. Prepare to maximise EU Carbon Border Adjustment Mechanism (CBAM) compliance while decreasing challenges. Guidelines, factsheets, and PowerPoint presentations make this bundle the ideal compliance solution. Take advantage of this excellent opportunity to plan early and ensure a flawless import/export journey! https://www.customsmanager.info/post/revolutionize-your-cbam-strategy-with-the-ultimate-2024-cbam-bundle-download-now Exporters voice concerns Exporters said they had accepted the CBAM reporting standards for now, although they are still in the transitional phase. They did, however, convey their want for further information on the emissions default value. Early in November, Indian Business and Industry Minister Piyush Goyal told regional media that the EU's proposed carbon price on imports is misguided and would be disastrous for the nation's manufacturing sector. The minister claimed that India is developing a mechanism of its own to impose a price on carbon. EU's Carbon Border Adjustment Mechanism (CBAM) - Full Training (4 Hours) Our Customs Training Center offers a comprehensive EU's Carbon Border Adjustment Mechanism (CBAM) training program that spans 4 hours - delivered online and pre-recorded so that you can watch it anywhere, anytime, and from any device. Our expert instructor, Arne Mielken, will guide you through the CBAM's intricacies, ensuring you thoroughly understand the process. This course covers the full range of CBAM topics, giving you the knowledge and skills you need to succeed. Whether you're new to CBAM or looking to refresh your existing skills, our Full Training program is the perfect choice. Join us and take your CBAM knowledge to the next level. On Demand: https://www.customsmanager.org/product-page/eu-s-carbon-border-adjustment-mechanism-cbam-full-training-4-hours Live: https://www.customsmanager.org/events (Various dates) Iron and Steel The China Iron and Steel Association also said at the beginning of November 2023 that CBAM will increase export costs and function as a roadblock to Chinese exports. Among the products covered under CBAM for the steel sector are pig iron and DRI/HBI, semi-finished steel, slab, billet, certain manufactured steel products, screws, nuts, bolts, and other similar iron and steel items. Ferroalloys and scrap are not included. Japanese steelmakers recently emphasised that the approach disadvantaged imported goods by unfairly forcing importers to provide data that EU steel producers do not. Japan's 1.85 million tonnes of annual steel shipments to the EU, which make up over 5% of its total exports, might suffer greatly if the reporting system is implemented as planned. Concerns over CBAM are also held by steel industries in Argentina, Turkey, India, and South Korea. They claim that the strategy violates WTO regulations and hurts imports relative to producers in Europe. Due to the restricted capacity for renewable energy, European steelmakers are also worried about the circumstances surrounding the CBAM changeover. Before the system is completely implemented, South Korean steel makers requested the government to convince the EU to permit domestic carbon emission estimates for a longer length of time. India also wants the EU to accept its carbon credit trading programme. Aluminium Aluminium is lightweight and strong, used in aeroplanes, cars, and solar panels. The most energy-intensive metal in the industry is so-called “solid electricity”. Aluminium manufacture accounts for 3% of industrial emissions, according to the International Energy Agency, more than aeroplane emissions. European aluminium makers worry that a carbon border tax gap might enable exporters like China to flood the EU with cheap, emissions-heavy metal. There is a loophole that allows widespread greenwashing of imported aluminium products and undermines CBAM's carbon leakage prevention. This loophole may be exploited to remelt and market garbage as carbon neutral in Europe. This is, so it is claimed, because it permits remelted aluminium offcuts to be marketed as zero-carbon goods, even if the raw material was produced from coal or other fossil fuels. as a result, this would push non-EU producers to produce as much waste as possible for remelting and selling to Europe. Europe's aluminium producers' claims follow concerns about a lack of rebates for exports containing taxed imported aluminium, cars and cans containing highly polluting aluminium being allowed in without paying for metal production emissions, and the loss of free emission allowances. Download Report: The aluminium value chain and implications for CBAM design Cement The cement industry is the second-largest industrial emitter worldwide, contributing 4% of the EU's CO2 emissions. Cement production considerably adds to CO2 emissions. The cement industry is the second-largest industrial emitter, contributing 7% of world CO2 emissions, and demand is expected to rise. Cement is essential for many activities, such as buildings and infrastructure, and is crucial for the net-zero transition. In 2027, the 27 EU member states will levy third-country cement exporters for their CO2 emissions from EU sales. It is well known across the cement industry that companies from Turkey to Australia have manufactured and transported their cement into the EU at high CO2 costs while still outperforming local suppliers. Lawmakers fixed the problem by giving EU businesses free ETS credits, including cement. The EU ETS is a key policy for addressing climate change and reducing emissions. The cap-and-trade approach allows corporations to swap allowances within a set limit. The ETS provides free emission permits for up to 100% of cement sector emissions to address carbon leakage problems and prevent relocation, making EU cement manufacturing uncompetitive with lower-cost, higher-emissions imports. Download: "Concrete policies to underpin the cement transition" Hydrogen Not included in the original proposal from the European Commission, the CBAM will now include hydrogen along with cement, steel, aluminium, fertilisers, and energy. The European Commission, European Parliament, and Council engaged in interinstitutional talks, or trilogues, which resulted in the inclusion of hydrogen in the EU CBAM. It was expected that hydrogen (CN 28041000) would be crucial to the EU being carbon neutral by 2050. Hydrogen finds its use in several areas and may be utilised as feedstock, fuel, energy carrier, or storage solution. The EU does not yet have a commodities market for liquid hydrogen. The most popular way of supplying hydrogen is via captive production, which ensures a steady supply of the gas. Approximately 90% of the total capacity for producing hydrogen is generated internally or recovered (as a byproduct) by industrial customers. The so-called "merchant hydrogen," which is generated and sold under long-term contracts by other parties, only makes up about 10% of the overall capacity for hydrogen production.Eleven Here, hydrogen is marketed as a specialty chemical for use in industry and, sometimes, as a means of transportation energy. It is anticipated that the EU hydrogen market would eventually transition to a mostly liquid commodities market that uses Guarantees of Origin as certifications. Download Report: The inclusion of hydrogen in the EU CBAM Conclusion In conclusion, it is clear that CBAM continues to be a source of contention and dispute among the corporate community. It is also clear that there is much ambiguity over the right approach for importers to submit their emissions to European Union bodies. There is valid worry about the absence of correct information, which forces importers to depend on possibly deceptive data for reporting reasons. Concerns have been raised about the capacity and desire of CBAM product manufacturers to provide the necessary data and correctly compute emissions. Furthermore, it is typical for importers to get items via wholesalers, who in turn obtain them from the open market. As a result, locating and monitoring the origin of the CBAM product is a considerable difficulty. The difficulty in determining the original manufacturer raises concerns regarding the practicality of such an undertaking. The failure of importers to complete proper reports on January 31, 2024 is related to the many outstanding issues. 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Welcome to the latest edition of "The Export Controls & Sanctions Manager." This weekly magazine is dedicated to keeping you informed about export controls and trade sanctions in the US, EU, and UK. We understand that these topics are of significant importance to some of our readers, which is why we have created a separate blog entry for them. Our team will update this magazine every week to ensure that we cover these topics thoroughly. We value your feedback, so please don't hesitate to send us your comments via email. Period covered 07.11.2023 - 13-11-2023 Content Highlight Reads of the Week Due Diligence Export Controls Updates U.S. Export Controls EU Export Controls UK Export Controls Sanctions Updates EU Sanctions UK Sanctions U.S. Sanctions What to do if I have questions regarding these updates? Sources Unlock all exclusive posts and make sure you stay fully up-to-date. Access Our NEW FAQ to answer all your questions: https://www.customsmanager.info/plans-pricing Highlight Reads of the Week UN: Can AI and Autonomy be Used Responsibly in the Military? AI and autonomy are increasingly being utilised in the military sector, particularly by the United States and its coalition partners, to enhance their defence capabilities. We look at what was decided at the UN yesterday. provide summary and context. https://www.customsmanager.info/post/un-can-ai-and-autonomy-be-used-responsibly-in-the-military Meet the Trade Compliance Superhero! An unsung hero is an invaluable member of a team, whose contributions are crucial for the success of the group, yet they frequently go unnoticed or receive insufficient recognition for their efforts. What is their role? https://www.customsmanager.info/post/meet-the-trade-compliance-superhero Due Diligence For all updates, see: https://www.customsmanager.info/all-news/categories/due-diligence 1) Ensuring Transparency: Insights on the EU List of Prominent Public Functions (PEPs) The European Union List of Prominent Public Functions, sometimes known as the PEPs, has been made public. https://www.customsmanager.info/post/ensuring-transparency-insights-on-the-eu-list-of-prominent-public-functions-peps 2) EU: Companies trading globally must respect human rights & environment (Due Dilligence) In 2022, the European Union adopted a proposal called the Directive on Corporate Sustainability Due Diligence. This proposal aims to promote sustainable and responsible corporate behaviour across the global value chains. https://www.customsmanager.info/post/eu-companies-trading-globally-must-respect-human-rights-environment-due-dilligence 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 1) Strengthening International Efforts: Combating Weapons of Mass Destruction Fight against the proliferation of weapons of mass destruction. Find out about the EU strategy against the proliferation of Weapons of Mass Destruction https://www.customsmanager.info/post/strengthening-international-efforts-combating-weapons-of-mass-destruction 2) Understanding the Implications of EU Dual Use Regulation 821-2020 Cyber controls and increased control requirements mean exporters need to double up on their due diligence efforts. We explain the what, when, how... https://www.customsmanager.info/post/eu-export-ccontrol-dual-use ⇒ UK Export Controls 1) Navigating UK Export Controls: A Guide to the Latest Open General Export Licences (OGEL) Discover the ins and outs of UK Export Controls with our comprehensive guide to Open General Export Licences - which were updated last week. Stay compliant and informed. Date of last e-update: 14.11.2023 https://www.customsmanager.info/post/uk-open-general-export-licences-list 2) UK Export Controls - What You Must Know About OGELs Learn about UK General Licences - OGELs and how they may be used to accelerate your export processes. https://www.customsmanager.info/post/uk-export-control-ogel ⇒ U.S Export Controls Export controls are a powerful tool for the USA to achieve its foreign and security policy goals. Violations are punished severely, even outside the US. As non-US companies face increasing demands on compliance programs, export control has become a major focus. Violating the export control law can land you on the "US sanctions list" with serious consequences. Stay updated with the latest developments to protect yourself from potential penalties. 1) BIS: Update Conference on Export Controls and Policy The Bureau of Industry and Security (BIS) is rescheduling the Update Conference on Export Controls and Policy from November 28–30, 2023 to March 27-29, 2024. Details here: https://www.customsmanager.info/post/us-commerce-department-s-bureau-of-industry-and-security-bis-latest-updates 2) Temporary Denial Order (TDO) to Russian Individuals and Entities Seven individuals and three companies—Nikolay Goltsev, Salimdzhon Nasriddinov, Kristina Puzyreva, Oleg Zenchenko, Yekaterina Vetoshkina, Pavel Chernikov, Vladimir Bochkarev, SH Brothers Group Inc. (SH Brothers), SN Electronics, Inc., and Suntronic F.Z.E. (Suntronic)—had their export rights suspended by a BIS Temporary Denial Order (TDO). These ten are accused of participating in a global procurement ring that illegally purchased millions of dollars of dual-use electronics for Russian end users, including military businesses. https://www.customsmanager.info/post/us-commerce-department-s-bureau-of-industry-and-security-bis-latest-updates 3) ITAR: State/DDTC Seeks Comments on Form DS–7786, Requests for Advisory Opinion Notice of request for public comment and submission to OMB of proposed collection of information. https://www.customsmanager.info/post/itar-state-ddtc-seeks-comments-on-form-ds-7786-requests-for-advisory-opinion 4) Commerce/BIS Reinstates Rossiya Airlines Export Privilege Denial Under Section 766.24 of the Export Administration Regulations, 15 C.F.R. Parts 730-774 (“EAR” or “the Regulations”), I grant the Office of Export Enforcement (“OEE”)'s request to renew the temporary denial order (“TDO”) issued in this matter on May 12, 2023. I find that renewing this order is necessary in the public interest to prevent an imminent violation of the Regulations and that an extended period is appropriate because Rossiya Airlines (“Rossiya”) has committed repeated, ongoing, and/or continuous apparent EAR violations. https://www.customsmanager.info/post/us-commerce-department-s-bureau-of-industry-and-security-bis-latest-updates 5) Firearms Export Licences STOPPED BIS said recently that it will no longer be granting new export licences for certain firearms, related components, and ammunition that are within its jurisdiction for a duration of about ninety days. During this "pause" period, authorities will further assess the current weapon export control review regulations to see if any changes are required. Commerce claims the investigation will be finished "urgently," allowing authorities to assess and lessen the likelihood that weapons may be transferred to groups or pursuits that uphold regional instability, violate human rights, or more effectively encourage criminal activity. Click here to review an FAQ sheet issued by the BIS: https://www.customsmanager.info/post/us-commerce-department-s-bureau-of-industry-and-security-bis-latest-updates 6) State/DDTC: All DECCS Users Must Log Into DECCS Before 17 Nov 2023 On Nov 17th, DDTC will be migrating to the FedRAMP High instance of a multifactor authentication solution to maintain a robust security posture and protect information stored within DECCS. As part of this process, all users should log into DECCS prior to Nov 17th, which will ensure your account information and passwords are automatically synced with the new upgraded instance. If you maintain multiple DECCS accounts, please ensure that you log in to all accounts you wish to retain access to. Once complete, no further action will be required at this time beyond the regular DECCS login process. Any users who do not log into their DECCS account may be locked out and unable to access DECCS without assistance in the future. 7) Bureau of Industry and Security and FinCEN Issue Joint Notice and New Key Term for Reporting Evasion of U.S. Export Controls Globally BIS and FinCEN issued a joint notice highlighting a new Suspicious Activity Report (SAR) key term (“FIN-2023-GLOBALEXPORT”) for financial institutions to reference when reporting potential efforts by individuals or entities seeking to evade U.S. export controls not related to Russia’s invasion of Ukraine. FinCEN and BIS previously issued two joint alerts in June 2022 and May 2023 urging financial institutions to be vigilant against potential Russian export control evasion in response to Russia’s illegal invasion of Ukraine. Financial institutions are encouraged to continue to use the key term “FIN-2022-RUSSIABIS” when filing SARs related to suspected Russian export control evasion. More here: https://www.customsmanager.info/post/us-commerce-department-s-bureau-of-industry-and-security-bis-latest-updates 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 1) Venezuela: Council reviews restrictive measures The Council extended its restrictive measures for six months instead of one year to 14 May 2024 due to Venezuela's situation. This includes a prohibition on firearms and internal repression equipment, a travel ban, and an asset freeze on 54 people. One deceased person was eliminated from the list during the measure review. Find out more: https://www.customsmanager.info/post/understanding-the-impact-of-eu-sanctions-on-venezuela 2) Understanding the Latest EU Sanctions on Libya: A Comprehensive Briefing Libya is currently subject to sanctions. Background, lists and latest legal updates are here. Date of latest Update: 14-11-2023 https://www.customsmanager.info/post/sanctions-briefing-libya 3) EU: Consolidated Sanctions List of Persons, Groups, Entities, and Organisations Discover the ultimate resource for EU sanctions: Download the consolidated list of persons, groups, and entities subject to sanctions. Date of last update 14.11.2023 https://www.customsmanager.info/post/eu-consolidated-financial-sanctions-list 4) Unpacking the EU Sanctions on the Central African Republic: What You Need to Know The Central African Republic is currently subject to financial sanctions. Find out why and access all relevant EU documents. Date of last Update. 14.11.2023 5) Assessing the Impact of EU Sanctions on Türkiye's Drilling in the Mediterranean Sea What restrictive measures are imposed considering Türkiye's unauthorised drilling activities in the Eastern Mediterranean? Date of Last Update: 14.11.2023 https://www.customsmanager.info/post/eu-sanctions-turkey ⇒ UK Sanctions Updates 1) New Russian Listings On November 10, 2023, the UK changed Vadym Oleksandrovich Tregub's entry in compliance with the sanctions against Russia. This individual is still vulnerable to asset freezes, transportation fines, and travel restrictions. On November 9, 2023, the UK took Sergey Stognienko off its list of people under sanctions. Mr. Stognienko was appointed to the management board of Bank Otkritie, a Russian financial services company, in September of 2022. Noted by OFSI. On November 8, 2023, the UK announced the designation of 29 new sanctions against individuals and groups involved in the strategic, oil, and gold industries in Russia. North Gold PLC and Highland Gold Mining Ltd., two of Russia's largest gold producers, are among the newly designated entities. Additionally, a network based in the United Arab Emirates, which includes Paloma Precious DMCC and Howard Jon Baker, is purportedly responsible for channelling gold revenues to Russia. Find out more and access notices: https://www.customsmanager.info/post/uk-latest-listing-of-sanctioned-persons-entities-organisations-etc 2) UK: Latest Listings of Sanctioned Individuals etc. (All Countries + Topics) All the latest changes to UK Sanctions Lists against individuals, entities, and organisations. All updates are on one page. Date of last update 14.11.2023 https://www.customsmanager.info/post/uk-latest-listing-of-sanctioned-persons-entities-organisations-etc 3) UK Russian Licence amended OFSI amends General Licencerelating to Russian Travel: On November 10, 2023, this licence was modified by OFSI. The amendment clarifies that the general licence only permits the purchase of tickets from a designated person listed in the licence or one of their subsidiaries for passenger rail or passenger air travels starting in or within Russia. https://assets.publishing.service.gov.uk/media/654e32dc6a650f0012bf47eb/10.11.2023_Russia_Travel_General_Licence.pdf https://www.customsmanager.info/post/uk-latest-listing-of-sanctioned-persons-entities-organisations-etc 4) Caution: Do not misuse gold in order to evade penalties. On November 8, 2023, the UK’s National Crime Agency (NCA) sent a red alert to financial institutions about the use of gold as a way to evade sanctions. The purpose of the alert was to raise awareness and encourage preventative action. Among other things, the alert contained the following information: (i) the relevant sanctions measures; (ii) an overview of typical circumvention methods; (iii) some indicators of circumvention of sanctions; and (iv) industry guidelines from other organisations. Download the document https://www.customsmanager.info/post/british-authorities-warn-against-misusing-gold-for-sanctions-evasion 5) A UK court rejects SG and ING's sanctions defence interim payment to EuroChem. The UK High Court denied LLC EuroChem North-West-2 (EuroChem)'s November 3, 2023 request that Société Générale (SG) and ING Bank (ING) deposit money into a UK or EU-frozen account or court. Eurochem sued SG and ING for on-demand bond payments; the jury decides in 2025. SG and ING refused to pay (the bonds' performance location) because of EU sanctions in France and Italy. . Find out more here: https://www.customsmanager.info/post/uk-sanction-court-cases 6) UK County Court denied Mazars and XTX Markets Technologies Ltd.'s summary judgement request. The Russian owner of financial technology trading company XTX, which was not sanctioned and has since renounced his Russian citizenship, claimed Mazars, which handled payroll, discriminated against it by refusing to work with it. Mazars refused Russian-owned clients by refusing more. XTX alleges 2010 Equality Act violations. Mazars used Section 44 of the SAMLA to argue that XTX were not treated less favourably than a hypothetical or real comparator by complying with UK sanctions. The County Court ordered a full trial for triable issues. Interpreting Mazars' email rejecting the invitation to provide services, choosing a comparator, and using s. 44 were the issues. Russia Regulations and UK sanctions are "front and centre to the issues in this case." Find out more here: https://www.customsmanager.info/post/uk-sanction-court-cases 7) UK High Court upholds “Brutus Allegations” on US sanctions non-compliance On November 8, 2023, the UK High Court rules on Iran sanctions. Four claims by 230 claimants against Standard Chartered (SC) allege that SC made false and misleading Iran sanctions market statements in its prospectuses from 2007 to 2019. SC settled with OFAC in 2012 and US enforcement agencies in 2019 over Iranian sanctions violations. These "Brutus Allegations" claim SCB's non-compliance was much more widespread and systematic than admitted. The UK High Court ordered a Brutus Allegations trial after the US District Court dismissed them. Approved Judgement: Standards Chartered plc v Various Claimants. Find out more here: https://www.customsmanager.info/post/uk-sanction-court-cases ⇒ US Sanctions Updates 1) A settlement agreement between OFAC and daVinci Payments Under the terms of the deal, DaVinci will pay a $206,213 penalty to resolve any possible legal responsibility it may have for allegedly breaking sanctions against Cuba, Iran, Syria, and Crimea. DaVinci made it possible for reward cards to be redeemed from people in these approved countries between 2017 and 2022. The fine is in line with OFAC's assessment that daVinci's actions were voluntary and non-egregious. Offical links and more https://www.customsmanager.info/post/us-sanctions-latest-updates 2) Issuance of Russia-related General Licenses "Authorising the Wind Down of Transactions Involving Certain Entities Blocked on November 2, 2023,".By this action, the licence is amended to make it clear that Public Joint Stock Company Saint Petersburg Exchange is covered by it. Saint Petersburg Stock Exchange was the entity's name as mentioned in the GL on November 2, 2023. Other than that, the GL remains unaltered. Details https://www.customsmanager.info/post/us-sanctions-latest-updates 3) OFAC has updated its Specially Designated Nationals and Blocked Persons List The United States is imposing further sanctions on over 200 individuals and entities in connection with Russia’s war against Ukraine. The Department of State is imposing sanctions on over 90 entities and individuals engaged in sanctions evasion and those complicit in furthering Russia’s ability to wage its war against Ukraine. The sanctions focus on individuals and entities abetting Russia’s unconscionable war against Ukraine by providing Russia with much-needed technology and equipment from third countries. Additionally, these actions take aim at Russia’s domestic industrial base, which is seeking to reinvent itself as the maintainer of Russia’s war machine. With these designations, Treasury is disrupting producers, exporters, and importers of nearly all of the high-priority items identified by the international coalition imposing sanctions and export controls on Russia. https://www.customsmanager.info/post/us-sanctions-latest-updates 4) Treasury Designates Virtual Currency Money Launderer for Russian Elites and Cybercriminals Treasury imposes consequences on money launderer responsible for moving funds on behalf of Russian elites and ransomware actors https://www.customsmanager.info/post/us-sanctions-latest-updates 5) Burma Sanctions Update Burma-related Designations; Issuance of Burma-related Directive 1 and Frequently Asked Questions https://www.customsmanager.info/post/us-sanctions-latest-updates 6) U.S. Extends China Sanctions: What It Means for Trade Relations with China U.S. President Keeps China Companies Subject to Restrictions https://www.customsmanager.info/post/u-s-extends-china-sanctions-what-it-means-for-trade-relations-with-china 7) U.S. President to be voice of Uyghurs?!? In a letter to President Biden, the Chairs of the CECC urged the President to act as the “voice” for Uyghurs residing in the United States who are afraid to publicly speak up for family members who have vanished or are being held in the Xinjiang Uyghur Autonomous Region (XUAR) due to PRC police and security forces using “intimidation and other tactics to coerce” them into remaining silent. 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). About Customs Manager’s Customs & Global Trade Intelligence Services The Premium Professional Legislative Monitoring Service (PLM) is a research and curation service which checks for legislative updates from official government websites based on the selected jurisdictions and topics. Paid Plan subscribers can access regular law change notifications to ensure they never miss a significant legal change on www.customsmanager.info – a website dedicated to customs & trade intelligence. At the same time, they save valuable time by engaging our dedicated trade specialists to carry the monitoring out for them. Premium subscribers also unlock all content on the Customs Manager’s Ltd. website, including our Customs & Trade Blog on www.customsmanager.info , providing vital thought leadership development services to empower them to trade effectively, efficiently and, of course, compliantly, across borders. Premium Subscribers can add jurisdictions and topics for an additional charge. About Customs Manager Ltd. We aim to empower people with import, export and transport responsibilities with helpful advice, insightful training and relevant trade intelligence services. We devote all our passion and energy to helping businesses grow faster cross-border. Working with us means having your own multilingual Customs Manager on standby to help you trade effectively, efficiently and, of course, compliantly wherever you want to go. Includes Brexit support and the ability to lodge customs declarations + Rules of Origin Stay in Touch · Website: www.customsmanager.org · E-Mail: info@customsmanager.org · YouTube: https://www.youtube.com/c/CustomsManagerLtd · Twitter: @customsmanager · Linked In: https://www.linkedin.com/company/69768402/admin/ Important Notice Customs Manager Ltd. owns the copyright in this document, except for external documents and links we refer to or make available. You are not allowed to use this information in any way that infringes its intellectual property rights. You may have to hold a valid licence to use this information. A licence can be obtained by becoming a Paid Plan subscriber to the Customs Managers’ Customs & Trade Intelligence service, also known as Professional Legislative Monitoring (PLM). As a Paid Plan subscriber, you may download and print this information which you may then use, copy or reproduce for your internal non-profit-making purposes. However, you are not permitted to use, copy or reproduce this information to profit or gain. In addition, you must not sell or distribute this information to third parties, not members of your organisation, whether for monetary payment or otherwise. This information is intended to serve as general guidance and not constitute legal advice. The application and impact of laws can vary widely based on the specific facts involved. This information should not be used as a substitute for consultation with professional legal or other competent advisers. Before making any decision or taking action, consult a Customs Manager Ltd. professional. In no circumstances will Customs Manager Ltd be liable for any decision made or action taken in reliance on the information contained within this document or for any consequential, special or similar damages, even if advised of the possibility of such damages.

Venezuela is currently subject to financial sanctions. Find out why and access all relevant EU documents. Date of last Update. 14.11.2023

The European Union List of Prominent Public Functions, sometimes known as the PEPs, has been made public.

Fight against the proliferation of weapons of mass destruction. Find out about the EU strategy against proliferation of Weapons of Mass Destruction

U.S. President Keeps China Companies Subject to Restrictions

AI and autonomy are increasingly being utilised in the military sector, particularly by the United States and its coalition partners, to enhance their defence capabilities. We look at what was decided at the UN. At the launch event for the Political Declaration on Responsible Military Use of Artificial Intelligence and Autonomy, Under Secretary Benjamin Jenkins addressed the endorsers, highlighting the importance of global action for responsible AI development and use. The Declaration aims to establish measures for responsible behavior and a mechanism for states to discuss and address challenges faced by militaries when adopting AI systems. The United States is committed to doing its part and looking forward to working with partners on this endeavor for years to come. The Declaration aims to establish strong norms for responsible development and deployment, enabling nations to harness the potential benefits of AI systems in the military domain while encouraging steps that avoid irresponsible, destabilizing, and reckless behavior. The 45 endorsers joined together to lay the groundwork for responsible military use of AI and autonomy, and the initiative encourages broad participation from as many endorsers as possible to achieve a shared understanding on these issues. The Declaration of the United Nations General Assembly (UNGA) has launched the first multilateral instrument and State dialogue on the full range of uses of AI and autonomy in the military domain. It provides a basis for a more concrete dialogue on what "responsible" means in practice and how to exercise "appropriate care" in practical applications. The Declaration also emphasizes the need to widen the aperture to consider the full range of military applications and focus more explicitly on AI rather than just autonomy. It calls on States to ensure military AI capabilities have explicit, well-defined uses and are designed and engineered to fulfill those intended functions. It also calls for transparent methodologies, data sources, design procedures, and documentation to enable internal traceback and corrective actions in case of failure. The Declaration underscores the importance of safety, calling for appropriate safeguards to mitigate risks of failures in military AI capabilities. The initiative aims to foster collaboration among endorsers by providing a foundation for exchanges, sharing best practices, expert-level exchanges, and capacity-building activities. The Declaration is designed to be flexible, allowing for progress in shared understanding of AI-enabled systems. The success of the initiative should be measured in the progress made in enabling and motivating States to implement these practices. The initiative is also characterized by its inclusivity, involving a large and diverse group of states from different regions and perspectives. The goal is to reduce risks and uncertainties brought by AI tools in the military domain and strengthen compliance with international humanitarian law. The initial version of the Declaration, which included a commitment to maintain human control and involvement for actions critical to nuclear weapons employment, was removed to avoid stumbling blocks for states to endorse. The current Declaration is a strong statement of shared norms of responsible behavior and an excellent foundation for further dialogue and engagement with the international community. Political Declaration on Responsible Military Use of Artificial Intelligence and Autonomy BUREAU OF ARMS CONTROL, DETERRENCE, AND STABILITY Fundamentally, it is our belief that technology with global impact deserves global action. And so, to provide order and stability in the midst of global technological change, I firmly believe that we must be guided by a common set of understandings among nations. […] The United States will continue to work with our allies and partners to apply existing international rules and norms to AI and work to create new rules and norms. VICE PRESIDENT KAMALA HARRIS, NOVEMBER 1, 2023 The Political Declaration on Responsible Military Use of Artificial Intelligence and Autonomy provides a normative framework addressing the use of these capabilities in the military domain. Launched in February 2023 at the Responsible AI in the Military Domain Summit (REAIM 2023) in the Hague, the Declaration aims to build international consensus around responsible behavior and guide states’ development, deployment, and use of military AI. The Declaration provides a basis for exchanging best practices and building states’ capacities, which will allow endorsing states to share experience and ideas. The United States will convene a regular dialogue among endorsing states to further promote international support for and implementation of these responsible practices. Endorsing states will meet in the first quarter of 2024 to begin this next phase. The United States encourages all states to support the Declaration and join with other endorsing states to promote responsible military use of AI and autonomy. Endorsing States Endorsing States as of November 13, 2023 include: Armenia Albania Australia Austria Belgium Bulgaria Canada Croatia Cyprus Czech Republic Denmark Estonia Finland France Georgia Germany Greece Hungary Iceland Ireland Italy Japan Kosovo Latvia Liberia Libya Lithuania Luxembourg Malawi Malta Montenegro Morocco Netherlands North Macedonia Portugal Romania San Marino Singapore Slovakia Slovenia Spain South Korea Sweden Türkiye United Kingdom United States 4-In-1 Support Services: How to get more support 1. Customs & Global Trade Updates (Fee Subscription): www.customsmanager.info 2. Customs & Global Trade Consultancy & Advice (Free First Call): https://www.customsmanager.org/consultancy 3. Customs & Global Trade Training & Education: https://www.customsmanager.org/education-training 4. Compliant & efficient UK Customs Clearance: https://www.customsmanager.org/customs-agent Connect with us on socials LinkedIn: https://www.linkedin.com/company/customs-manager-ltd/ X: @customsmanager YouTube: https://www.youtube.com/c/CustomsManagerLtd Get in Touch · Website: www.customsmanager.org · E-Mail: info@customsmanager.org About Customs Manager’s Customs & Global Trade Intelligence Services The Premium Professional Legislative Monitoring Service (PLM) is a research and curation service which checks for legislative updates from official government websites based on the selected jurisdictions and topics. Paid Plan subscribers can access regular law change notifications to ensure they never miss a significant legal change on www.customsmanager.info – a website dedicated to customs & trade intelligence. At the same time, they save valuable time by engaging our dedicated trade specialists to carry the monitoring out for them. Premium subscribers also unlock all content on the Customs Manager’s Ltd. website, including our Customs & Trade Blog on www.customsmanager.info , providing vital thought leadership development services to empower them to trade effectively, efficiently and, of course, compliantly, across borders. Premium Subscribers can add jurisdictions and topics for an additional charge. About Customs Manager Ltd. We aim to empower people with import, export and transport responsibilities with helpful advice, insightful training and relevant trade intelligence services. We devote all our passion and energy to helping businesses grow faster cross-border. Working with us means having your own multilingual Customs Manager on standby to help you trade effectively, efficiently and, of course, compliantly wherever you want to go. Includes Brexit support and the ability to lodge customs declarations and making sense of rules of origin, customs classification and customs valuation to make but a few. Important Notice Customs Manager Ltd. owns the copyright in this document, except for external documents and links we refer to or make available. You are not allowed to use this information in any way that infringes its intellectual property rights. You may have to hold a valid licence to use this information. A licence can be obtained by becoming a Paid Plan subscriber to the Customs Managers’ Customs & Trade Intelligence service, also known as Professional Legislative Monitoring (PLM). As a Paid Plan subscriber, you may download and print this information which you may then use, copy or reproduce for your internal non-profit-making purposes. However, you are not permitted to use, copy or reproduce this information to profit or gain. In addition, you must not sell or distribute this information to third parties, not members of your organisation, whether for monetary payment or otherwise. This information is intended to serve as general guidance and not constitute legal advice. The application and impact of laws can vary widely based on the specific facts involved. This information should not be used as a substitute for consultation with professional legal or other competent advisers. Before making any decision or taking action, consult a Customs Manager Ltd. professional. In no circumstances will Customs Manager Ltd be liable for any decision made or action taken in reliance on the information contained within this document or for any consequential, special or similar damages, even if advised of the possibility of such damages.

On November 8, 2023, the UK’s National Crime Agency (NCA) sent a red alert to financial institutions about the use of gold as a way to evade sanctions.

Stay up to date with the latest UK-sanction court cases! Explore our blog for insightful news and analysis on the legal battles shaping the business landscape. Date of last update 14.11.2023

Learn about UK General Licences - OGELs and how they may be used to accelerate your export processes.

Discover the ins and outs of UK Export Controls with our comprehensive guide to Open General Export Licences. Stay compliant and informed. Date of last e-update: 14.11.2023