Regulatory & International Trade | RIT - Helping Businesses Clear Regulatory Hurdles in Europe

Quarterly Sanctions Update | Q2 2024

by Sabine Naugès, Raminta Dereskeviciute and Michal Chajdukowski | Jul 8, 2024 | Sanctions & Export Control

On June 24, 2024, the European Union adopted its 14th sanctions package.

While the focus of this package was to curb the violation and circumvention of sanctions through the introduction of due diligence obligations for non-EU subsidiaries, or the expansion of “no re-export to Russia” clause requirement, ample other amendments were also introduced, such as those relating to transfer of IP rights, or divestment. The list of restricted goods has also been significantly expanded and additional persons and entities have been added to the list of sanctioned persons.

On June 29, 2024, the EU also expanded its sanctions against Belarus in order to align with the goals of the 14th sanctions package. Additional sanctions under the Hamas and Palestinian Islamic Jihad and Sudan regimes were also published.

In this Quarterly Sanctions Update, we summarise the most recent and significant amendments introduced, or proposed, by the EU and the United Kingdom between April and July 2024.

Click here to read the full [...]

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Export Controls in the Aeronautics, Space and Defense Sector | Conference Key Takeaways

by Sabine Naugès | Jun 20, 2024 | Sanctions & Export Control, Transport & Logistics

Export control in the aerospace and defense (ASD) sector is a critical and complex issue.

At the European level, one of the main standards for export control in the ASD sector is the regulation governing dual-use goods. However, within the European Union, regulations can vary significantly between Member States.

This regulatory landscape indicates the necessity for businesses in the ASD sector to navigate a “manifold control” environment, where multiple authorizations may be required, reflecting the sector’s strategic complexity and the importance of compliance with diverse export control regime.

In our latest event, organized in partnership with the French Compliance Society, we discussed these issues and more with Philippe Clerc, Emmanuel Dupic and Edouard Leeleea.

Click here to download our key takeaways for a full overview of the session. [...]

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Private Equity Firms Beware | Inflation Reduction Act Likely to Trigger FSR Obligations

by Sabine Naugès and Stéphane Dionnet | Jun 11, 2024 | Foreign Subsidies, Public Procurement

One year after its entry into force on July 12, 2023, the Foreign Subsidies Regulation (FSR) continues to make headlines. The FSR allows he European Commission (EC) to investigate financial contributions granted by non-EU governments to companies active in the European Union and to impose measures to redress any uncovered distortive effects.

Contrary to expectations, the EC was quick to implement this new investigative tool to remedy the distortions caused by the allocation of foreign subsidies on the internal market. Read more in our previous post here.

In addition, it is highly likely that FSR-based controls will be strengthened in the coming years as national protectionism increases. For example, the Inflation Reduction Act (IRA), adopted by the USA in 2022 and introducing a nationwide support plan including production subsidies and tax incentives, is likely to subject US companies to FSR notification obligations and possibly to reinforced ex officio investigations by the EC.

Although the recent examples of FSR implementation have provided a better understanding of the EC’s priorities, many questions remain for economic operators, and even more so for private equity (PE) investors.

Spotlight on the “Partner Countries” Exemption from Sanctions against Russia

by Raminta Dereskeviciute, Fabio Cozzi, Sabine Naugès, Dr. Alexa Ningelgen, Renate Prinz, Michal Chajdukowski, Benoit Feroldi, Kai Grandpierre and Dr. Tim Oliver Weill | Jun 7, 2024 | Sanctions & Export Control

From June 20, 2024, EU companies with a presence in Russia will no longer be able to rely on the “partner countries” exemption and will be required to obtain, or rely on, a licence to provide business services and/or software to their Russian entities.

Competent authorities of the EU Member States responsible for granting licences required pursuant to EU sanctions have taken markedly different approaches in implementing this change.

At the same time, UK sanctions against Russia never contained the “partner countries” exemption and UK companies providing business services to their Russian entities were always required to apply for a licence. In this article, we analyse how the German, French, Italian and the UK regimes are addressing this issue.

Click here to read our full article.

German Authorities Take Action to Accelerate Export Control Procedures

by Dr. Alexa Ningelgen and Dr. Tim Oliver Weill | May 24, 2024 | Sanctions & Export Control

The authorities responsible for export controls in Germany are currently focused on simplifying and accelerating their existing administrative procedures. Since fall 2023, they have enacted three packages of measures, which, among other things, significantly expand the catalog of general export authorizations (GAs). This offers companies substantial time and cost advantages, as the export projects covered by the GAs do not have to undergo individual licensing procedures anymore. The following provides an initial overview of the legislative amendments in this regard.

Older Posts »

Quarterly Sanctions Update | Q2 2024

Export Controls in the Aeronautics, Space and Defense Sector | Conference Key Takeaways

Private Equity Firms Beware | Inflation Reduction Act Likely to Trigger FSR Obligations

Spotlight on the “Partner Countries” Exemption from Sanctions against Russia

German Authorities Take Action to Accelerate Export Control Procedures

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