In the just published 2014 OFAC (*) Civil Penalties Information Chart four out of the ten companies who settled  with the US authorities since January 2014 for alleged breaches of US trade sanctions are non-US companies. Three of them are EU companies.

Whereas the number of OFAC enforcement actions per year has been declining in the last decade, the financial amounts involved per year have been rising. Even though the biggest fines or settlements have usually been with financial institutions, other sectors, and both large and small companies as well as private individuals can and do get hit by US measures.

The WorldECR journal of export controls and sanctions has published a focus edition on export control activities in Brussels and some of its  export control lawyers.

It can be downloaded from here: http://www.worldecr.com/wp-content/uploads/WorldECR-Brussels-Focus.pdf

John Grayston will be speaking at the WorldECR conference on sanctions and export control in London in November 2013.  He will talk on how the EU will shape a new export control regime.

Full details of the conference are at: http://www.worldecr.com/conference/

Almost all goods controlled in the EU as dual use are controlled as a result of EU Regulation 428/2009.  Certain goods can also be controlled at EU level for exports to specific third countries due to EU sanctions against those countries.

Compliance personnel in EU companies will usually be well be aware of the fact that the European and national competition authorities can raid both company premises and their employees’ private homes, subject to certain conditions.

The following document summarizes the more than 250 substantive changes made to the EU List of Dual Use items set out in Annex I of the EU’s Export Control Regulation 428/2009.

Regulation (EU) 388/2012 : http://trade.ec.europa.eu/doclib/docs/2012/may/tradoc_149517.pdf

A new Annex I to the EU’s Export Control Regulation 428/2009 will enter into force on 15 June 2012. The recently adopted Regulation 388/2012 amends the current Annex I which contains the EU list of Dual Use items.

On 30 June the EU Commission adopted a consultative  GREEN PAPER on the future direction of EU Dual Use controls.  The title of the paper is "Ensuring Security and Competitiveness in a Changing World".