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“Lost in Transposition” – Commission Targets 18 Member States Over Sanctions Enforcement Gaps

On July 24, 2025, the European Commission opened infringement procedures against 18 Member States for failing to fully transpose Directive (EU) 2024/1226 by the May 20, 2025 deadline....more

E(U)xterritoriality of EU Sanctions: The No Russia Clause

The EU is going extraterritorial, and it is doing so through private contract. It is a pretty neat trick. As a general rule, EU regulations do not apply extraterritorially. This policy is a bit pointed, intended to stand...more

Protective Packaging: The EU’s Economic Security Package Changes the Landscape in Global Technology Controls

The EU plans to step up controls on its home grown technology. That is the short version. The longer version is a (pretty dry) recitation of the proposed legislation and whitepapers that were published last week as the...more

Arming for a Trade War: The EU Proposes an Unprecedented Anti-Coercion Regulation

Scope of the Proposed Regulation - The Regulation would apply where a third country interferes in the legitimate sovereign choices of the Union or a Member State, by applying or threatening to apply measures affecting...more

A New Era of Export Controls Begins in the EU: The Revised EU Dual-Use Export Controls to Promote Human Rights

On May 10, 2021, the EU adopted its new, revised version of Regulation (EC) No 428/2009 (the “Regulation”). It is widely acknowledged to be the first major reform to the structure of the EU’s export control regime since...more

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