April - 2020

EU modifies export restrictions on personal protective equipment

Due to the ongoing epidemiological crisis caused by the COVID-19 disease, the European Union has modified export restrictions on personal protective equipment (PPE). EU Regulation 2020/568 reduces the list of products that require export authorization, extends geographical exceptions, and requires Member States to swiftly grant authorization for the export of PPE for humanitarian purposes. This Regulation entered into force on 26th April 2020 and applies for 30 days.

BAFA amends foreign trade regulation

Germany’s ‘Bundesamt für Wirtschaft und Ausfuhrkontrolle’ (BAFA) has announced an amendment to the Foreign Trade and Payments Ordinance (found here). This is the fourteenth regulation amending the Foreign Trade and Payments Ordinance and it came into force on 21st April 2020. The most notable change in this amendment is in § 12 paragraph 3, sentence 3 and concerns the obligation to name the exporter in the export declaration, given that the exporter is not identical to the cu

OFAC issues Venezuela-related general license and amended FAQ

On 10th April 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License No. 5C entitled “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After July 22, 2020.” For further information see the OFAC Recent Actions notice and related Frequently Asked Question (FAQ).

OFAC amends North Korea Sanctions Regulations

On 9th April 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the North Korea Sanctions Regulations, 31 C.F.R. part 510. These amendments allow for the further execution of the North Korea Sanctions and Policy Enhancement Act of 2016, as amended by the Countering America’s Adversaries Through Sanctions Act of 2017 and the National Defense Authorization Act for Fiscal Year 2020. The changes came into effect on 10th April 2020; for fur

US State Department gives update on operational status

The U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) has published an update on its status of operations. The DDTC reports that although electronic application systems are currently in normal operational mode, longer than normal processing times are expected due to the reduction of staff available to review applications. Additionally, the DDTC has established a new protocol for submissions pursuant to ITAR Section 127.12. For further details please read

EU removes export restrictions on medical protective equipment for several countries, ATLAS publishe

The European Union has removed export restrictions on medical protective equipment for several countries, in particular European Free Trade Association (EFTA) countries (Norway, Iceland, Liechtenstein, Switzerland). For further details see the announcement from Germany’s ‘Bundesamt für Wirtschaft und Ausfuhrkontrolle’ (BAFA) and EU Regulation 2020/426. In addition, German customs (Generalzolldirektion, "Zoll") added a new licensing code for ATLAS ("Automatisiertes Tarif- und

OFSI penalizes Standard Chartered Bank

The United Kingdom’s Office of Financial Sanctions Implementation (OFSI) imposed a monetary penalty against Standard Chartered Bank (SCB) for a total of £20,471,809.83. This penalty was given for breaches of Article 5(3) of EU Council Regulation 833/2014 (£7,693,233.50) and of Regulation 3B of The Ukraine (European Union Financial Sanctions) (No.3) Regulations 2014 (£12,778,576.33). Between 2015 and 2018 SCB made a series of loans to Denizbank A.Ş., a bank that was almost com