Regulatory & International Trade | RIT | Helping businesses clear legal regulatory hurdles in Europe

Relaxation of Long-Standing Restrictions on Foreign Investment in the Healthcare Sector in China

by Peter Lu | Nov 27, 2024 | Foreign Investment

The demand for medical services in China is growing, with the country’s ageing population set against its potential for economic development. A joint circular released by China’s Ministry of Commerce, National Health Commission and the National Medical Products Administration in September signals a relaxation of China’s long-standing restrictions on foreign investment in the healthcare sector. Given a decline in foreign direct investment (FDI) in China generally, the announcement has garnered significant global attention.

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New US Sanctions Against Gazprombank and Several Russian Financial Institutions

by Sabine Naugès, Raminta Dereskeviciute and Michal Chajdukowski | Nov 25, 2024 | Sanctions & Export Control, Energy

The US Treasury’s Office of Foreign Assets Control (OFAC) has implemented sanctions on additional Russian financial institutions, notably Russia’s Gazprombank and several foreign subsidiaries. These blocking sanctions prohibit US persons and entities from transacting with Gazprombank or its listed subsidiaries, as well as any entity owned 50% or more by Gazprombank or any other sanctioned entity. OFAC additionally designated more than 50 smaller Russian banks, as well as more than 40 securities registrars, and a list of Russian nationals operating in the financial services sector.

Understanding French Export and Re-Export Prohibitions: Ministry of Armed Forces Releases FAQ on Non Re-Exportation Certificates

by Sabine Naugès and Michal Chajdukowski | Nov 22, 2024 | France, Sanctions & Export Control

On October 10, 2024, the French Ministry of Armed Forces released an FAQ relating to a Non-Re-Exportation Certificate (NRC), available in French here (FAQ). This document provides practical guidance to military companies exporting equipment covered by the prohibition on export or re-export to sanctioned countries. The FAQ complements the existing guidelines for completing certificates required by French authorities (see here).

Concerned companies should be mindful of consulting the FAQ when preparing their NRCs. It is crucial to closely follow the guidance from the French Ministry of Armed Forces in order to avoid any follow-up questions which may delay the transaction or trigger any further investigation from the French authorities. This is particularly important in circumstances where sanctions regimes, notably against Russia, are becoming increasingly significant and more strictly enforced (read our latest update here).

Quarterly Sanctions Update | Q3 2024

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

Although the European Union and the United Kingdom did not introduce new sanctions against Russia over the summer, they extensively focused on the implementation of the existing measures and their enforcement. This week, however, a new package of sanctions aimed at tackling hybrid operations by the Russian government has been agreed upon, and is expected to be published in the coming weeks. In the same period, the Court of Justice of the European Union (CJEU) issued a number of landmark judgments clarifying certain aspects of the EU sanctions regime and has, in one instance, openly disagreed with the interpretation of the regime by the European Commission.

Furthermore, in line with the overarching goal of EU sanctions against Russia, which is to support Ukraine, for the first time, the European Union has transferred profits from frozen assets of the Russian Central Bank to the European Peace Facility and the Ukraine Facility, which will used the monies in support of Ukraine’s military and reconstruction needs.

Finally, acknowledging the current geopolitical situation in the Middle East, the European Union and United Kingdom continued to issue new sanctions against Hamas and Iran. The United Kingdom has also revoked certain licences allowing the sale of [...]

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EU Member States Implement Additional Measures to Regulate Export of Non-Listed Dual-Use Items

by Raminta Dereskeviciute, Sabine Naugès and Michal Chajdukowski | Oct 4, 2024 | Sanctions & Export Control

Member States in the European Union have taken additional measures beyond Regulation (EU) 2021/821 to control exports of dual-use items. More than half have extended authorization requirements for non-listed dual-use items suspected of being intended for military “end-use.” Additionally, five Member States have imposed export authorization for cyber-surveillance items linked to internal repression and serious human rights violations. The official publication of these additional national measures has just been released.