On April 28, 2020, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) published two final rules and one proposed rule[1] that will result in tighter restrictions on exports, reexports, and in-country transfers of dual-use items subject to the Export Administration Regulations (EAR) and controlled for national security reasons to China, Russia, Venezuela, and a number of other countries. Companies involved in exports and reexports of controlled items to these countries should carefully review the changes.
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Dual Use
EU Publishes Non-Binding Guidance on Internal Compliance Programmes for Dual-Use Trade Controls
By Till Müller-Ibold, François-Charles Laprévote & Katherine Nobbs on
Posted in Dual Use, Europe, Europe Trade, European Union, Export Control, International Trade, Sanctions
On August 5, 2019, the European Commission (“Commission”) published its official Guidance on Internal Compliance Programmes (“Guidance”).[1] The Guidance aims to clarify and harmonize implementation of Regulation 428/2009 on Dual-Use Goods[2] (“Dual-Use Regulation”) by competent Member State authorities (“national export authorities”) and EU-based exporters of dual-use goods (“exporters”). While the Guidance is non-binding, national export authorities will take it into careful account when considering applications to export, transit or broker dual-use items.
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