On October 9, 2025, the US Senate passed its version of the National Defense Authorization Act (“NDAA”) for Fiscal Year 2026, paving the way for the chamber to formally negotiate with the US House of Representatives on a compromise version of the legislation. A must-pass piece of legislation that funds Department of Defense (“DoD”) operations [...] The post US Senate Passes Defense Policy Bill with Biotechnology, Export Control, Foreign Investment, and Other Trade Provisions appeared ...| Global Sanctions and Export Controls Blog
In Japan, there were two major updates to its export control and sanction regime announced in the past few weeks. 1. Reimposition of Sanctions Against Iran On 29 September 2025, Japanese government announced the reimposition of the following measures under the Foreign Exchange and Foreign Trade Act, in response to United Nations Security Council Resolution [...] The post Japan Export Control Updates: Reimposed Sanctions Against Iran and Entities Added to End User List appeared first on Global...| Global Sanctions and Export Controls Blog
On 28 August 2025, France, Germany, and the United Kingdom (the “E3”) formally triggered the “snapback” mechanism under the Joint Comprehensive Plan of Action (“JCPOA”), citing Iran’s continued non-compliance with its nuclear-related commitments. This move has been followed by weeks of unsuccessful negotiations at the United Nations aimed at extending the JCPOA framework. As a [...] The post Sanctions on Iran Reinstated Following Triggering of JCPOA Snapback by E3 appeared first...| Global Sanctions and Export Controls Blog
Baker McKenzie and The Association of Women in International Trade (WIIT)- Preparing for a Sanctions Investigation Date: Wednesday, October 15 Time: 5:00 – 7:30 PM EDT Location: In-person at the Baker McKenzie DC Office (815 Connecticut Ave NW Washington, DC 20006) Registration: Click Here Guest Panelists and Moderator: The post Baker McKenzie and The Association of Women in International Trade (WIIT)- Preparing for a Sanctions Investigation appeared first on Global Sanctions and Export Con...| Global Sanctions and Export Controls Blog
As of October 1, 2025, the US government partially shut down as federal funding lapsed for numerous US government agencies, including those engaged in export controls, sanctions, and foreign investment. As a result, companies should expect licensing processing and reviews to be significantly delayed. Investigative activity and enforcement actions related to US national security, however, [...] The post US Government Shutdown and Impact on Certain Trade Agencies appeared first on Global Sancti...| Global Sanctions and Export Controls Blog
On September 29, 2025, after some months of speculation, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an interim final rule “Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities” (the “IFR”). The IFR immediately introduces a new “Affiliates Rule,” essentially a “50% ownership flow-down rule,” into the Export [...] The post BIS Introduces New “Affiliates Rule” Significantly Expanding Entity List, MEU List, and...| Global Sanctions and Export Controls Blog
On October 7th, a global panel of Baker McKenzie’s trade and customs practitioners host a webinar sharing their insights on the global state of India trade relations, as well as the trends we’re seeing with respect to India trade and opportunities these present. Topics to be covered include: The webinar will take place at 4:00 PM [...] The post Upcoming Webinar: India Trade and Tariffs – Global Trends and Opportunities appeared first on Global Sanctions and Export Controls Blog.| Global Sanctions and Export Controls Blog
Following the EU’s 18th sanctions package and the latest developments of the UK’s sanctions against Russia, the Governments of Australia and Japan also introduced additional measures against Russia respectively on 18 and 12 September 2025. Among other measures, they have agreed with other G7 countries to phase out Russian oil imports in response to the [...] The post Australia, Japan align with EU and UK and introduce further sanctions against Russia, alongside further UK and EU sanctions...| Global Sanctions and Export Controls Blog
Effective 25 September 2025, Poland has officially partially opened its border with Belarus. This move was announced by the Polish Prime Minister on 23 September 2025. From 25 September 2025, the road border crossing in Terespol (for personal movement) and Kukuryki (for commercial movement which is permitted exclusively for vehicles registered in the EU, EEA, [...] The post Poland Reopens its Border with Belarus appeared first on Global Sanctions and Export Controls Blog.| Global Sanctions and Export Controls Blog
Join us in Santa Clara, California on Thursday, November 13, for an exclusive in-person forum on Trade Policy in an Era of Geoeconomics, Tariff Wars& National Security Risks. This in-person event will precede our webinar series – the 46th Virtual Annual Year-End Review of Import/Export & Trade Compliance Developments Conference. This in-person forum offers a unique opportunity to engage directly with industry experts and peers, participate in [...] The post SAVE THE DATE: Global...| Global Sanctions and Export Controls Blog
On 13 August 2025, the Swiss government adopted the Ordinance on the harmonization of sanctions ordinances (“Ordinance”), introducing a number of provisions relating to financial sanctions and their exceptions and derogations in relation to 14 of the 28 sanctions regimes in force in Switzerland (already briefly mentioned here). The Ordinance will come into effect on [...] The post Switzerland amends several sanctions ordinances to harmonize provisions on financial sanctions and humanitari...| Global Sanctions and Export Controls Blog
On 8 September 2025, the EU Commission adopted a Delegated Regulation updating Annex I of the Regulation (EU) 2021/821 (“EU Dual-Use Regulation”). Although the changes have not yet entered into force, they outline the likely amendments to the EU Dual-Use Regulation. Background Annex I of the EU Dual-Use Regulation lists dual-use items that require export authorization pursuant to Article [...] The post EU Commission Adopts Delegated Regulation Updating Annex I of the EU Dual-Use Regul...| Global Sanctions and Export Controls Blog
Effective 12 September 2025, Poland has officially closed all border crossings with Belarus until further notice. This move was announced by the Polish Minister of Interior Affairs on 10 September 2025, in response to the joint Russian-Belarusian military exercise “Zapad 2025”. From 12 September 2025, no commercial or person movement is possible through any of| Global Sanctions and Export Controls Blog
On June 1, 2023, Canada enacted the Special Economic Measures (Moldova) Regulations (the “Regulations”) in response to Russia’s ongoing war of aggression against Ukraine. The Regulations are targeted sanctions, which will serve to undermine Russia’s influence over Moldova and reaffirm its commitment to continue to use its sanctions regime to target foreign states that are| Global Sanctions and Export Controls Blog
There have been a number of fluctuating developments in the UN and EU’s approach to Iran over the past few weeks, with a further attempt to salvage negotiations in an agreement on 10 September. We set out further details herein, including consideration of the sanctions implications. Political Developments At the end of August, amid concerns [...] The post European Responses to Iran: snapping back? appeared first on Global Sanctions and Export Controls Blog.| Global Sanctions and Export Controls Blog
On August 26, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a final rule removing the Syrian Sanctions Regulations (31 CFR Part 542) from the Code of Federal Regulations (“OFAC Final Rule”). This action follows the issuance of Executive Order (“EO”) 14312 on June 30, 2025, which terminated the [...] The post OFAC and BIS Issue Final Rules Removing Syria Sanctions Regulations and Relaxing Export Controls for Syria appeared first o...| Global Sanctions and Export Controls Blog
On August 25, 2025, the US Department of Defense (“DoD”) issued a Final Rule amending the Defense Federal Acquisition Regulation Supplement (“DFARS”) to prohibit DoD contracting officers from awarding certain consulting services contracts to contractors where they or their subsidiaries or affiliates hold contracts and subcontracts that involve providing “consulting services” to “covered foreign entities” [...] The post New DoD Rule Targets Consulting Services Contractors that ...| Global Sanctions and Export Controls Blog
On August 28, 2025, Canada announced amendments to the Special Economic Measures (Moldova) Regulations (the “Regulations”) sanctioning Russian collaborators in Moldova. The amendments list an additional sixteen individuals and two entities under the Schedule of the Regulations and took effect on August 28, 2025. These sanctions are announced in the context of Moldova’s upcoming parliamentary elections, which will| Global Sanctions and Export Controls Blog
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
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
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
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
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