Giani Pandey has been invited once again to speak at the Singapore Summit on Export Controls Compliance.
The next round of sanctions have been adopted and we are now waiting for their publication. The suggestions are that more individuals, companies active in dual use products and companies in the financial services sector will be affected. This then would mark a further development of the SMART sanctions adopted at the end of July.
As we cannot yet see the new measures it is worth just noting the three key issues that should be taken into account when we finally do review the text:
Since our last blog entry on the issue (here), the EU has adopted the Regulation imposing the EU import ban on goods and certain services from Crimea and Sevastopol. The Regulation, which came into force on 25 June 2014, contained two exceptions: (i) a grandfather clause for contracts and (ii) goods presented to the Ukrainian authorities to confirm their origin. The EU published however on the 4th of July a correction relating to the second exception.
At its meeting of 23 June 2014, the Council of the European Union decided that from the 25th of June onwards goods originating in Crimea and Sevastopol may no longer be imported into the European Union, except if they have been granted a certificate of origin by the Ukrainian authorities. Furthermore, providing financial and insurance services related to the import of such goods will equally be prohibited. Such total import ban measures are relatively exceptional for the EU.
The EU adopted further sanctions against Russia on Friday. Leaving to one side the political aspects, from a purely commercial level, for companies subject only to EU jurisdiction (as compared to those subject to EU and US measures) the current EU sanctions are unlikely to have any direct commercial impact.