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While the UK-EU trade negotiations were forced to move to virtual due to COVID-19, the UK Sanctions Unit pressed forward with a series of webinars geared toward preparing the Trade for the end of the transition period. We wanted to provide this summary of the changes covered by the UK government (on 19 Nov 2020) to help customers stay up to speed.

The Transition Period was established to provide trading partners with tools such as transitional Open General Export License (OGEL) which allows companies time to comply with the new regulations. This transitional OGEL expires on December 31st, 2020.

What UK companies who export dual-use items to the EU need to know:

The Sanctions and Anti-Money Laundering Act 2018 is the regulatory statute that governs the newly established rules coming into effect on January 1st, 2021. Companies need to be familiar with the new legal framework and pay particular attention to changes in the UK specific language, even though policy will remain relatively the same overall. If after review of the new statutes, you find that the nature of your business is not permitted under the UK sanctions, companies must register with SPIRE to obtain licenses or apply an OGEL to cover their activity going forward. It is important to note that licenses previously obtained from the UK will not be accepted under the EU sanctions following the end of the transition period. Inversely, only UK issued licenses will be accepted under the new UK sanctions.

Another important callout, the structure of the sanctions lists are also changing. Companies should be prepared to review your trade partners against the new UK Sanctions List, as well as the OFSI Consolidated List of Financial Sanctions. Depending on your business, it may be necessary to review both lists with the knowledge that there may be substantial changes under the new regimes. The UK Government is encouraging companies to reference the most up to date guidance by visiting their UK sanctions website https://www.gov.uk/guidance/uk-sanctions.

Michelle Frennier is Director, Solution Consulting, specializing in customs and compliance, at BluJay Solutions

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