February - 2020

OFAC publishes new RPPR-related FAQs

On 20th February 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published two new Frequently Asked Questions (FAQs) regarding the Reporting, Procedures and Penalties Regulations (RPPR). The new FAQs are concerning the 06/21/2019 Amendment to the RPPR. Follow this link to read OFAC’s Recent Action.

UK changes list of permitted destinations for OGELs

On 18th February 2020, the United Kingdom’s Department for International Trade: Export Control Joint Unit (ECJU) published a notice to exporters regarding changes to permitted destinations on a number of open general export licences (OGELs). Yemen has been removed as a permitted destination on a number of dual-use OGELs; Lebanon has been removed as a permitted destination on 2 OGELs; the Italian continental shelf has been added as a permitted destination on 2 OGELs; Turkey ha

US v. Huawei: superseding indictment announced and TGL renewed

On 13th February 2020, the U.S. Department of Justice (DOJ) announced a superseding indictment against Huawei Technologies Co. Ltd. (Huawei) and subsidiaries in federal court in Brooklyn, New York. The defendants include Huawei, Huawei Device Co. Ltd., Huawei Device USA Inc., Futurewei Technologies Inc., Skycom Tech Co. Ltd., and Huawei’s Chief Financial Officer Wanzhou Meng. The 16-count indictment from the DOJ includes charges of conspiracy to violate the Racketeer Influenc

UK changes inspection procedures

On 6th February 2020, the UK’s Export Control Joint Unit (ECJU) announced that beginning immediately, businesses will be informed of the “exact date when an inspection of their records will take place.” Although ECJU will still attempt to give businesses 4-6 weeks advance notice of inspection dates regarding the use of open licences and electronic standard individual export licences (SIELs), they will no longer offer alternative dates. For further details please read ECJU’s n

UK launches Global Tariff Policy and announces future import/export plans

On 6th February 2020, the UK’s Department for International Trade announced that is developing a new UK Most Favoured Nation (MFN) tariff schedule. This regime, known as the UK Global Tariff, will enter into force on 1st January 2021. To inform the UK Global Tariff, the UK government has launched a public consultation period that will end on 5th March 2020. Additionally, on 10th February 2020, the UK announced that it plans to treat all UK exports and imports equally after th

OFAC issues Mali Sanctions Regulations

On 6th February 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued regulations to implement Executive Order 13882, “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Mali.” These regulations are scheduled to take effect and be published in the Federal Register on 7th February 2020. For more information see OFAC’s recent action.

OFSI and ECJU inform about post-Brexit transition phase

The UK’s Office of Financial Sanctions Implementation (OFSI) has issued Financial Sanctions Guidance for the post-Brexit transition phase (ending on 31st December 2020). During the transition phase the UK is bound by EU sanctions, but can also bring autonomous UK sanctions into force under the Sanctions and Anti-Money Laundering Act 2018 (the Sanctions Act). This guidance document published by OFSI does not apply to financial sanctions regimes that already come under the Sanc