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Global Trade & Sanctions Law

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New Sanctions and Export Controls in Global Response to the Attempted Annexation of Ukrainian Territory

In the final few days of September, the U.S. and global allies issued a number of sanctions and export controls against actors who have supported Russia’s referendums in Ukraine and related attempts to annex four Ukrainian territories. The referendums have been condemned by the Group of 7 (G7) nations, which…

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G7 Agrees on Price Cap for Russian-Origin Oil and Related Products – What Companies Need to Know

Takeaways The G7 has announced consensus on a price cap for Russian origin oil and petroleum products to be implemented across a wide coalition of countries. The cap would be implemented by prohibiting services related to the maritime transportation of Russian-origin crude oil and petroleum products unless the products are…

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U.S. Commerce Department Implements Export Controls on Four New Emerging and Foundational Technologies

On August 15, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule introducing new controls on four “emerging and foundational technologies” that were identified during the December 2021 plenary meeting of the multilateral Wassenaar Arrangement. These items are two substrates of ultra-wide bandgap…

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EU Issues a “Maintenance and Alignment” Regulation while UK Publishes a Succession of Amendments to Its Sanctions Regime against Russia.

EU update On July 21, 2022, the EU published its “maintenance and alignment” package of sanctions. This latest package seeks to tighten existing sanctions, perfect their implementation, and strengthen their effectiveness. In summary, this latest package has the following effects: Extending the list of restricted items which may contribute to…

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State Department Issues Two Open General Licenses Authorizing Reexports and Retransfers of Certain Defense Articles for Australia, Canada and the UK

On July 13, 2022, as part of a new pilot program, the Department of State’s Directorate of Defense Trade Controls (DDTC) issued two open general licenses (OGLs) permitting certain reexports and retransfers of unclassified defense articles subject to the International Traffic in Arms Regulations (ITAR) within or between Australia, Canada,…

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Further UK and EU Restrictive Measures Introduced Against Russia and Belarus

EU introduces a sixth package of sanctions. On June 3, 2022, the EU adopted a sixth package of sanctions against Russia which includes economic, individual, media and diplomatic measures. (See the full text of the regulation here.) These measures relate to the following key areas: Oil embargo The package includes…

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Uyghur Forced Labor Prevention Act Goes into Effect: What Companies Need to Know about U.S. Guidance on Implementation and Enforcement

Key Takeaways: The Uyghur Forced Labor Prevention Act (UFLPA) went into effect on June 21, 2022, and requires the U.S. Customs and Border Protection (CBP) to presume that all goods manufactured wholly or in part in the XUAR, or by the entities identified by the U.S. government on June 17,…

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Overview of the Proposed “Reverse CFIUS” Process via the National Critical Capabilities Defense Act of 2022

On June 12, 2022, a bipartisan group of Senate and House lawmakers announced agreement on a new draft of the National Critical Capabilities Defense Act of 2022 (NCCDA), which would establish an expansive outbound review mechanism for investments and other transactions in specified countries of concern, including China. The draft…

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Russia Takes Steps to Allow Use of Foreign-Held IP Rights without Consent of the Rightsholder

We’ve covered in depth the array of sanctions-related activity brought by the international community against Russia in response to the conflict in Ukraine. As these measures mount, Russia has in return taken steps to alleviate some of the pressure such sanctions have brought to bear. In “Russia Introduces Tools for…

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Further Sanctions Issued Against Russia: Services, Export Controls and Visa Restrictions

On May 8, 2022, the White House announced a number of new measures in response to Russia’s ongoing war in Ukraine. The new measures include prohibitions on new categories of services to Russia by U.S. persons; export controls on certain industrial goods; and the addition of several shipping companies, bank…