On 18 July 2025, the European Commission (EC) launched a public consultation on future measures to protect the European Union (EU) steel sector from unfair trade practices. The deadline to provide input is 18 August 2025....more
In separate developments, the European Commission (the “Commission”) opened a public consultation on the extension of the Carbon Border Adjustment Mechanism (CBAM) to downstream products and on additional anti-circumvention...more
On Thursday, the European Commission opened a public consultation on a proposed list of U.S. imports that could face European Union (EU) countermeasures if current negotiations between the EU and the U.S. fail to reach a fair...more
Background - The war in Ukraine has taken a new diplomatic turn in recent weeks. Having historically aligned with the European Union (EU) and United Kingdom (UK) on its condemnation of Russia’s war in Ukraine, and the need...more
3/17/2025
/ Asset Freeze ,
Economic Sanctions ,
EU ,
Foreign Policy ,
Foreign Relations ,
International Trade ,
National Security ,
NATO ,
Russia ,
UK ,
Ukraine ,
United States
The European Union (EU) had said repeatedly that it will retaliate in case of U.S. tariffs, which the EU sees as unjustified. The EU preferred (and attempted) a negotiated solution but moved swiftly to retaliation once the...more
3/14/2025
/ Aluminum Sales ,
Enforcement Actions ,
EU ,
European Commission ,
Imports ,
International Trade ,
Regulatory Agenda ,
Regulatory Requirements ,
Section 232 ,
Steel Industry ,
Supply Chain ,
Tariffs ,
Trade Policy ,
Trade Relations
In 2021, the European Union (EU) updated the EU Dual-Use Regulation, setting unified standards for EU member states to control exports of dual-use items. A key addition in Regulation (EU) 2021/821 is Article 5’s “catch-all...more
12/2/2024
/ Cybersecurity ,
Dual Use Goods ,
Due Diligence ,
EU ,
Exporters ,
Exports ,
Misuse of Information ,
Regulatory Agenda ,
Software ,
Surveillance ,
Telecommunications ,
Transparency
On 22 November 2024, the European Commission (the “Commission”) issued new frequently asked questions (FAQs) regarding the interpretation of the “Best Efforts” obligation in Article 8a of Council Regulation (EU) No. 833/2014...more
Key Takeaways - On 3 July 2024, the Council of the European Union (the “EU Council”) published its revised Update of the EU Best Practices for the effective implementation of restrictive measures (“Best Practices”).This...more
7/23/2024
/ Best Practices ,
Buyback Programs ,
Economic Sanctions ,
EU ,
Limited Liability Company (LLC) ,
Majority Shareholders ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Shell Corporations ,
Trusts ,
UK
EU’s 12th Sanctions Package - On 19 December 2023, the Council of the European Union (EU) together with the Commission published its 12th round of sanctions....more
12/27/2023
/ Asset Freeze ,
Banking Sector ,
Cryptocurrency ,
Economic Sanctions ,
EU ,
European Economic Area (EEA) ,
Export Controls ,
Fund Transfers ,
G7 ,
Imports ,
Information Sharing ,
Insurance Industry ,
Licensing Rights ,
Metals ,
Oil Prices ,
Pipelines ,
Propane ,
Reporting Requirements ,
Russia ,
SDN List ,
Software ,
Technology Sector ,
Telecommunications ,
Trade Restrictions ,
Transparency ,
UK
On 23 June 2023, the European Union (EU) adopted a new package of economic sanctions against Russia. In addition to other measures, the 11th sanctions package has specifically widened prior financial restrictions applicable...more
Court of Justice of the European Union sets Binding Rules on the Contractual Impact of the EU Blocking Regulation
The EU Blocking Regulation (the “Regulation”)1 prohibits compliance by EU persons with certain U.S....more
Key Points -
On 11 June 2021 the European Union (the “EU”) published Regulation (EU) 2021/821 (the “Recast Regulation”) in its Official Journal, which marked the final step with respect to modernizing its existing dual use...more
The U.K. and the EU conclude the EU-UK Trade and Cooperation Agreement, which entered into force on December 31, 2020.
The Agreement provides guidance on origin rules that must be met for products to benefit from duty-free...more
1/8/2021
/ Cooperation Agreement ,
Country of Origin ,
EU ,
Export Controls ,
Exports ,
Member State ,
Regulatory Standards ,
Supply Chain ,
Trade Agreements ,
Trade Relations ,
UK ,
UK Brexit
- On July 24, the European Commission (EC) published an updated report (the “Report”) on the progress made by member states in implementing measures aimed at addressing the national security risks and mitigation strategies...more
8/4/2020
/ 5G Network ,
Emerging Technology Companies ,
EU ,
European Commission ,
Foreign Direct Investment ,
Member State ,
National Security ,
Risk Mitigation ,
Security Risk Assessments ,
Supply Chain ,
Telecommunications
- There is increasing regulatory, commercial and media attention in the U.K. and the EU regarding the role of human rights in company supply chains.
- The U.K. and the EU are introducing specific measures around human...more
7/22/2020
/ Coronavirus/COVID-19 ,
Due Diligence ,
Environmental Social & Governance (ESG) ,
EU ,
Forced Labor ,
Human Rights ,
Investors ,
Modern Slavery Act ,
Proceeds of Crime Act 2002 (POCA) ,
Risk Assessment ,
Risk Mitigation ,
Slavery ,
Supply Chain ,
UK
On February 19, 2020, the European Commission (Commission) published proposals for the regulation of Artificial Intelligence (AI) with potentially far-reaching implications both for users and developers worldwide. The...more
3/11/2020
/ Artificial Intelligence ,
Corporate Counsel ,
EU ,
European Commission ,
Legislative Agendas ,
New Legislation ,
Popular ,
Regulatory Agenda ,
Research and Development ,
Technology Sector ,
White Papers
• On June 5, 2019, the European Union (EU) took a step forward with respect to modernizing its existing dual use legislation under Council Regulation (EC) No 428/2009 (the “EU Dual Use Regulation”), with the European Council...more
6/12/2019
/ Dual Use Goods ,
Economic Sanctions ,
Emerging Technology Companies ,
EU ,
Export Controls ,
Exports ,
Human Rights ,
Information Security ,
Member State ,
Supply Chain ,
The Wassenaar Arrangement
• On August 6, 2018, following President Trump’s decision to withdraw the United States from the JCPOA, the U.S. government announced the reimposition of sanctions on Iran’s automotive sector, its trade in gold and precious...more
8/17/2018
/ Blocking Statutes ,
Economic Sanctions ,
EU ,
Executive Orders ,
International Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Trade Relations ,
Trump Administration ,
Winding Down ,
Withdrawal
• The White Paper sets out in detail the shape and scope of the U.K.’s desired future “association” relationship with the EU post Brexit. The U.K. government hopes that it will accelerate negotiations with the EU with a view...more
• The U.K. and the EU have agreed on the substantive trade elements of the legal text set to govern the U.K.’s withdrawal from the EU (the “Withdrawal Agreement”). If the other outstanding elements of the Withdrawal Agreement...more
3/28/2018
/ Cross-Border Transactions ,
EU ,
EU Single Market ,
Free Trade Agreements ,
Intellectual Property Protection ,
International Relations ,
Member State ,
Referendums ,
Trade Policy ,
Trade Relations ,
UK ,
UK Brexit
• European Commission publishes survey on concept of “Specially Designed for Military Use,” and issues request for input for possible EU commercial policy measures targeting the United States
• Netherlands introduces...more
3/19/2018
/ Cloud Service Providers (CSPs) ,
Cloud Storage ,
Customs Valuation ,
Defense Sector ,
Draft Guidance ,
Encryption ,
EU ,
European Commission ,
Exports ,
Imports ,
Military Goods ,
Netherlands ,
Surveys ,
Tariff Classifications ,
Tariffs ,
Technology Sector
• A recent judgment of the European Court of Justice for bars the use of intercompany transfer prices for EU imports and EU customs duty purposes if (as is commonly the case) these are subject to retroactive adjustments.
...more
On August 4, 2017, the Council of the European Union (the “Council”) made six new designations to the list of persons subject to restrictive measures in respect of actions undermining or threatening the territorial integrity,...more
8/21/2017
/ Annexation ,
Asset Freeze ,
Crimea ,
Economic Sanctions ,
Energy Sector ,
EU ,
Export Controls ,
Oil & Gas ,
Power Plants ,
Russia ,
Siemens ,
Trade Restrictions ,
Travel Ban ,
Ukraine