Background Article 8a of Council Regulation (EU) 833/2014 (the “EU Russia Regulations”) imposes obligations on EU parents to undertake “best efforts” to ensure that activities conducted by their non-EU subsidiaries do not undermine EU sanctions targeting Russia and Belarus. This requirement, which was introduced in June 2024, raises complex questions about the scope of EU [...] The post EU Commission issues new guidance on “best efforts” obligations appeared first on Global Sancti...| Global Sanctions and Export Controls Blog
Please join Baker McKenzie and the Customs and International Trade Bar Association’s (CITBA) National Security and Sanctions Committee for a hybrid roundtable discussion on Tuesday, September 16, from 5:30 – 7:30 PM EDT. The discussion will focus on the current landscape of the Treasury’s inbound and outbound investment rules, including CFIUS updates and the evolving [...] The post Foreign Investment and National Security Roundtable appeared first on Global Sanctions and Export Controls...| Global Sanctions and Export Controls Blog
On August 25, U.S. Customs and Border Protection (“CBP”) issued a draft Federal Register notice to effectuate the President’s Executive Order (“EO”) on “Addressing Threats to the United States by the Government of the Russian Federation,” which imposed additional tariffs on imports of Indian origin due to India directly or indirectly importing Russian oil. Under these new tariffs, imports [...] The post CBP Effectuates Executive Order Increasing Tariffs by 25% for a total 50...| Global Sanctions and Export Controls Blog
On August 21, 2025, the European Union and United States unveiled their Framework on an Agreement on Reciprocal, Fair, and Balanced Trade (“Framework“). The Framework follows, and provides further detail to, the July announcement that the European Union and United States had agreed on broad terms of a trade deal. The Framework outlines the key [...] The post EU and US Announce Framework Trade Agreement appeared first on Global Sanctions and Export Controls Blog.| Global Sanctions and Export Controls Blog
As a first step towards implementing the EU’s 18th sanctions package, the Swiss government amended several annexes to the Ordinance on Measures in Connection with the Situation in Ukraine (“Ukraine Ordinance”) on 11 August 2025. The Swiss government also extended the lists of designated persons in the Ordinance on Measures against Belarus (“Belarus Ordinance”) and [...] The post Switzerland implements the new EU listings for Ukraine, Belarus and Moldova introduced in July, thereby i...| Global Sanctions and Export Controls Blog
On August 6, President Donald Trump issued an Executive Order on “Addressing Threats to the United States by the Government of the Russian Federation,” imposing additional tariffs on Indian imports. Under these new tariffs imports of most Indian goods will be subject to an additional 25% duty, which will stack on top of the 25% duty on [...] The post US Turns Up the Heat on Indian Imports over Purchases of Russian Oil Increasing Tariffs by 25% appeared first on Global Sanctions and Expo...| Global Sanctions and Export Controls Blog
Introduction On 22 July 2025, the UK Office of Financial Sanctions Implementation (“OFSI”), which is responsible for the enforcement of financial sanctions in the UK, opened a public consultation on proposed amendments to its civil monetary penalty procedures. The consultation (available here) seeks input on five key categories of amendments to OFSI’s current civil enforcement [...] The post UK OFSI Consultation on Civil Monetary Penalty Processes appeared first on Global Sanctions and ...| Global Sanctions and Export Controls Blog
On 18 July 2025, the UK Government announced a lowering of the Oil Price Cap (“OPC”) to further inhibit Russia’s ability to use oil revenues to finance its illegal invasion of Ukraine. The OPC was first introduced in December 2022 to reduce Russia’s oil revenues in response to the invasion of Ukraine that same year.| Global Sanctions and Export Controls Blog
In less than two weeks, we have seen Syria go from one of the most heavily sanctioned countries on the planet to a country well on the road to establishing normal trade relations with the Western world. The latest flurry of developments started on May 13, 2025, when President Trump caught much of the world| Global Sanctions and Export Controls Blog
Background The European Union continues to expand its sanctions regime against Russia and Belarus. The latest – the 18th – EU Russia/Belarus sanctions package was published on 19 July 2025, and included a range of additional sanctions, mainly targeting the Russian energy, banking and military industries, but also individuals and the Russian shadow fleet (see [...] The post EU Commission calls on Member states to transpose Directive setting minimum criminalisation standards for sanctions v...| Global Sanctions and Export Controls Blog
On 31 July 2025, the UK Office of Financial Sanctions Implementation (“OFSI”) announced that it had imposed a monetary penalty totalling GBP 300,000 on Markom Management Limited (“MML”), a provider of fiduciary, management, administration, bookkeeping and accounting services incorporated in the UK. The monetary penalty related to conduct in 2018 and a breach of the [...] The post UK Financial Sanctions Update: OFSI Imposes Monetary Penalty on Markom Management Limited appeared first o...| Global Sanctions and Export Controls Blog
On July 23, the White House unveiled its much-anticipated AI Action Plan, followed the same day by an Executive Order on “Promoting The Export of the American AI Technology Stack.” Following our earlier post considering the Action Plan from a multi-practice standpoint (US AI Vision in Action: What Businesses Need to Know About the White [...] The post US: What the New White House AI Action Plan and Executive Order Mean for Export Controls appeared first on Global Sanctions and Export Cont...| Global Sanctions and Export Controls Blog
In brief In recent years, intellectual property (IP) has become an increasingly important area of application for international sanctions. While sanctions have traditionally focused on restricting trade in goods, services, financial transactions and the movement of individuals, the scope has broadened to include intangible assets such as patents, trade secrets and software. This development reflects| Global Sanctions and Export Controls Blog
On July 22, 2025, the US Senate unanimously passed the Maintaining American Superiority by Improving Export Control Transparency Act (H.R. 1316), sending it to President Trump for his signature. The Act would amend the Export Control Reform Act of 2018 (“ECRA”) to require the Secretary of Commerce to submit an annual report to Congress on [...] The post US President Set to Sign Export Control Transparency Act Into Law appeared first on Global Sanctions and Export Controls Blog.| Global Sanctions and Export Controls Blog
On 18 July 2025, the European Union adopted its 18th package of sanctions against Russia, including by amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014. The EU also mirrored a number of measures and introduced additional designations in its Belarus sanctions by amending Regulation (EC) 265/2006. Adopted just two months after the 17th package, this [...] The post EU Adopts 18th EU Sanctions Package Against Russia and Introduces Additional Complimentary Measures Pursuant to Belaru...| Global Sanctions and Export Controls Blog
On 21 July 2025, the UK government issued the General Trade Licence: Russia Sanctions – Sectoral Software and Technology (the “Sectoral Software Licence”) under Regulation 65 of the Russia (Sanctions) (EU Exit) Regulations 2019 (the “UK Russia Regulations”). The Sectoral Software Licence came into force on 21 July 2025 and will expire on 20 October [...] The post UK issues General Licence in relation to business enterprise software under Russia sanctions appeared first on Global San...| Global Sanctions and Export Controls Blog
On 17 July 2025, the UK Office of Financial Sanctions Implementation (“OFSI”) launched a series of new online forms for parties looking to submit licence applications or report information such as suspected breaches of financial sanctions. The new forms aim to streamline the submission process and to avoid incomplete or incorrect submissions through the [...] The post UK Office of Financial Sanctions Implementation launches online forms for submitting licensing and reporting informatio...| Global Sanctions and Export Controls Blog
In brief On 14 July 2025, Malaysia’s Ministry of Investment, Trade and Industry (“MITI”) issued Directive No. 1/2025 (“Directive”), imposing controls on the export, transshipment, and transit of high-performance AI chips. The Directive is issued under Section 12 of the Malaysian Strategic Trade Act 2010 (“STA 2010”), which provides for a “catch-all” control mechanism, allowing [...] The post Malaysia Introduces New Export Control Directive for Advanced AI Chips appeared firs...| Global Sanctions and Export Controls Blog
At the Annual Compliance conference recently held in London, Baker McKenzie hosted a session on ‘The evolving national security, sanctions and export controls landscape’. This session introduced the concept of the “trade toolbox” — a growing set of measures designed to manage national security risks through trade and investment restrictions. Speakers highlighted the increasing complexity [...] The post Annual Compliance Conference summary: The evolving national security, sanctions a...| Global Sanctions and Export Controls Blog
On June 30, 2025, the White House reissued National Security Presidential Memorandum-5 (“2025 NSPM-5”) focused on Cuba policy that it published in largely the same form in the first Trump Administration (see the “2017 NSPM-5”). As acknowledged in Section 4(a) of the reissued document, much of the contents of the 2025 NSPM-5 was already implemented [...] The post White House Reissues Cuba-Related Presidential Memorandum from First Trump Administration and US State Department Updates ...| Global Sanctions and Export Controls Blog
On June 30, 2025, President Trump issued Executive Order 14312 (the “Syria EO”) terminating the U.S. comprehensive sanctions program targeting Syria, while also continuing to maintain and expand certain sanctions targeting former Syrian President Bashar al-Assad and others associated with the former Syrian regime. In addition, the U.S. State Department revoked the designation of Hay’at Tahrir [...] The post United States Lifts Comprehensive Syria Sanctions appeared first on Global Sanc...| Global Sanctions and Export Controls Blog
Blog Series: Navigating the Impending Global Sanctions Enforcement Storm – Reducing Risks of a Sanctions Investigation with Gap Assessments| Global Sanctions and Export Controls Blog
On 20 June 2025, the Swiss Federal Council announced that Switzerland is lifting its economic sanctions against Syria (see press release here). This decision is a move to align Switzerland with the EU’s decision of 27 May 2025 (see blog post here). The revision follows the initial easing of specific sanctions related to Syria’s energy| Global Sanctions and Export Controls Blog
Our Baker McKenzie’s Global Trade and Sanctions Practice recently held a snap webinar on Looking ahead to future developments in US, EU and UK Russia sanctions policy. The session discussed the current sanctions frameworks in relation to Russia, how these could be relaxed, and how the EU and UK may respond, drawing on past experiences where| Global Sanctions and Export Controls Blog
Canada amends sanctions related to settlements in West Bank| Global Sanctions and Export Controls Blog
As part of the Annual Compliance Conference webinar series, this session explored the evolving global sanctions landscape in relation to Russia, over three years since the first wave of sanctions following the outbreak of war in February 2022. The panel examined the current state of play, recent developments, and what may lie ahead for businesses| Global Sanctions and Export Controls Blog
On June 9, 2021, the Biden Administration issued Executive Order 14034, “Protecting Americans’ Sensitive Data from Foreign Adversaries” (“EO 14034”). EO 14034 revokes three executive orders issued by the Trump Administration that effectively banned certain Chinese connected software applications (“apps”) from operating in the United States. Although EO 14034 revokes these legal authorities and calls| Global Sanctions and Export Controls Blog
Since we published our blog post on the relaxation of the Syria sanctions over the weekend, there have been two more related developments this week: (1) US guidance on the Syria sanctions relaxed on Friday, May 23, and (2) the EU’s move to formally lift nearly all of its remaining sanctions on Syria. United States:| Global Sanctions and Export Controls Blog
As anticipated in its press release, the EU yesterday published in the Official Journal the first legal instruments underpinning its decision to progressively suspend its sanctions against Syria: Decision 2025/406/CFSP, Council Regulation 2025/407 and Council Implementing Regulation 2025/408. The measures include the suspension of a significant number of sanctions which have been in place for| Global Sanctions and Export Controls Blog
On 24 April 2025, the UK government published the Syria (Sanctions) (EU Exit) (Amendment) Regulations 2025, which took effect on 25 April 2025 (“Amending Regulations”). These new regulations amend the Syria (Sanctions) (EU Exit) Regulations 2019 to partially suspend a number of significant sanctions that have been in place for over a decade to reflect| Global Sanctions and Export Controls Blog
On November 26, 2021, the US Commerce Department published a Proposed Rule that would amend its Interim Final Rule on Securing the Information and Communications Technology and Services Supply Chain (“ICTS Regulations”) to specifically address connected software applications. The Proposed Rule would make changes prompted by Executive Order 14034 (“EO 14034”) to the ICTS Regulations.| Global Sanctions and Export Controls Blog
On June 19, 2024, Global Affairs Canada issued a Notice to Exporters regarding regulatory amendments to the Export Control List (ECL) that were previously approved by an order-in-council (Order) on May 31, 2024 (Amendments). The Amendments target goods and technology in relation to quantum computing and advanced semiconductors, following similar unilateral amendments (or proposed amendments)| Global Sanctions and Export Controls Blog
A company’s Russia-bound shipment gets stopped by customs authorities in the UK, which claim the products are prohibited for export to Russia. After confirming that the products are indeed restricted, the company initiates an internal investigation to get to the root cause of the problem and remediate. A whistleblower uses its employer’s compliance hotline to| Global Sanctions and Export Controls Blog