Licences, screening, sanctions
Under EU restrictive measures, the individual listings under Regulation 269/2014 were prolonged on 22 September for 36 months, to 22 September 2029; every renewal before it ran six months. The sectoral measures went to 12 months in June,...
I may be reading this from the wrong side, so please correct me. Since the end of June, China's customs administration has wanted the control answer on the export declaration itself. Announcement No. 77 reaches machine tools: lathes,...
Swiss export to Kuwait: Dual-use / licence assessment Hi all, I’m looking for some guidance regarding an upcoming export from Switzerland to Kuwait. The shipment contains equipment/components currently classified under the following HS...
Forgive me if this is obvious to everyone except me. It is my first day here, and my English is careful rather than quick. Our control list here moved twice this year. One revision took effect on 14 February. Another took effect on 16...
The list of chemicals that cannot leave the EU without an export notification gets longer on 1 October, and I have spent the back end of this week working out whether it is my name that carries it. The change is a delegated regulation...
A box in a transhipment shed shows you almost nothing. A through air waybill, a manifest, a flight in and a flight out. Hong Kong has reopened registration for its air transhipment exemption on strategic commodities. Applications close on...
Forgive me, Korea is not my market, so I am asking rather than telling. The notice that sets their strategic item list was amended with effect from 1 September, and two parts of it sit oddly together. Top end integrated circuits for AI...
Strictly speaking there is no ownership and control test. Regulation (EU) No 269/2014 freezes, in Article 2(1), whatever a listed person owns, holds or controls, and whatever simply belongs to them: alternatives, not a compound test. The...
The question reaching my desk: is Dubai an easier routing now. Read the easing itself. The Emirates came out of the chemical and missile country groups into the favoured one, which opens several licence exceptions. The strategic trade...
The real issue here is not export controls. It is whether your counterparty file can answer a question about ownership, because in two months it will be asked. On November 10 the suspension of the affiliates rule runs out, and unless...
Under EU law first. On 24 August the United States extended Executive Order 13902 to five sectors of the Iranian economy, technology among them, and those secondary sanctions reach companies with no US nexus. So when my screening flags an...
Under EU dual-use rules. The 2026 Annex I update, adopted on 14 September, creates 3A501.f for absolute inductive encoders of the rotary input type, and 3D001 adds their software. I have read the change note, not the parameters, so I...
