March - 2020

Germany announces implementation for electronic reporting of war weapons

On 20th March 2020, Germany’s ‘Bundesamt für Wirtschaft und Ausfuhrkontrolle’ (BAFA) announced that an amendment to the 2nd Implementing Ordinance to the War Weapons Control Act came into force. This amendment creates the legal basis for the electronic book of war weapons (eKWB), which is scheduled to start on 1st April 2020. The War Weapons Control Act (‘Kriegswaffenkontrollgesetz’ or KrWaffKontrG) requires that everyone who deals with war weapons to report the stock and cha

BIS extends comment period for public input on Huawei’s TGL extensions

On 25th March 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced that it will extend the public comment period on Huawei Temporary General License (TGL) Extensions through 22nd April 2020. The TGL for Huawei Technologies Co. Ltd. and its non-U.S. affiliates on the Entity List currently lasts through 15th May 2020 (reported on here).

OFAC issues extended Ukraine-related General Licenses

On 20th March 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) extended the expiration date of two Ukraine-related General Licenses (GL) until 22nd July 2020. GL No. 13N, “Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in GAZ Group,” replaces GL No. 13M in its entirety. GL No. 15H, “Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with G

Germany lifts national restrictions on exporting medical protective equipment and implements EU regu

On 19th March 2020, Germany’s ‘Bundesamt für Wirtschaft und Ausfuhrkontrolle’ (BAFA) announced that the national licensing requirement and restrictions on the exports of certain medical protective equipment (effective 12th March 2020 and reported on here) have been lifted. As a replacement the Federal Ministry of the Economy references an EU-wide regulation ((EU) 2020/402) that restricts export of certain medical protective equipment to non-EU states. Exporting medical protec

Canada passes US-Mexico-Canada agreement

On 13th March 2020, the United States-Mexico-Canada Agreement (USMCA) was passed by Canadian Parliament. Canada was the final country to ratify the USMCA, completing the approval process. For further information about the USMCA please see previous blog posts (here and here) and the statement by the U.S. Trade Representative (USTR) Robert Lighthizer.

BAFA changes the export ban on medical protective equipment

Germany’s ‘Bundesamt für Wirtschaft und Ausfuhrkontrolle’ (BAFA) has announced that the joint crisis management team, comprised of the Federal Ministry’s of the Interior (BMI) and of Health (BMG), has repealed the 4th March 2020 export ban on medical protective equipment. The previous export ban has been replaced with a new order of restrictions that provides new exceptions for and approvals on exporting medical protective equipment. The new order is effective 12th March 2020

BIS extends Huawei’s temporary general license

On 12th March 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) extended the temporary general license to Huawei Technologies Co., Ltd. (Huawei) until 15th May 2020 (from 1st April 2020). This extension applies to Huawei and 114 of its non-U.S. affiliates on the Entity List. For further information, please see the Federal Register entry and the Frequently Asked Questions (FAQs) published by BIS.

OFAC issues Venezuela-related GLs and FAQs

On 12th March 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued three amended General Licenses (GL): GL15C: Authorizing Transactions Involving Certain Banks for Certain Entities GL16C: Authorizing Maintenance of U.S. Person Accounts and Noncommercial, Personal Remittances involving Certain Banks GL36A: Authorizing Certain Activities Necessary to the Wind Down of Transactions Involving Rosneft Trading S.A. or TNK Trading International S

European Commission publishes notice on the use of pan-Euro-Mediterranean preferential rules of orig

On 2nd March 2020, the European Commission published the “Commission notice concerning the application of the Regional Convention on pan-Euro-Mediterranean preferential rules of origin or the protocols on rules of origin providing for diagonal cumulation between the Contracting Parties to this Convention” (2020/C 67/02) in the Official Journal of the European Union. This notice replaces notice 2019/C 333/03.

OFAC issues new FAQ about providing sanctioned humanitarian aid to Iran in response to the COVID-19

On 6th March 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a new Frequently Asked Question (FAQ) regarding provisions of humanitarian goods or assistance to Iran, in response to the COVID-19 outbreak, that are consistent with U.S. sanctions. For more information, see OFAC’s recent action and FAQ 828.

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