Sanctions
50% rule in sanctions screening and when a counterparty counts as listed
Aušra Šablinskienė27 Sep 2026
50% rule in sanctions screening and when a counterparty counts as listed
Whether an unlisted company is caught by the asset freeze applicable to its shareholder was tested twice in 2026. In EM System, a case under the Belarus regime, the Court of Justice confirmed a rebuttable control presumption at exactly 50%. In Inter Rao Lietuva, it required objective and sufficiently solid...
Sanctions
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EU sanctions: where listed and what consequencesAušra Šablinskienė03 Aug 2026
EU sanctions: where listed and what consequences
On 23 July 2026, the Council of the European Union formally adopted its 21st package of restrictive measures against Russia – the largest single round of designations since the full-scale invasion began. The package was agreed after weeks of difficult negotiations among member states. Understanding what the package actually does...
Sanctions
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Overview of the 20th EU sanctions package against Russia: what businesses should knowAušra Šablinskienė17 May 2026
Overview of the 20th EU sanctions package against Russia: what businesses should know
On 23 April 2026, the Council of the EU adopted the 20th package of sanctions against Russia. Below is an overview of the changes requiring particular attention due to specific exemptions, derogations for certain sectors, and differing dates of entry into force for some provisions.
Sanctions
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How can AI simplify compliance with international sanctions regimes?Aušra Šablinskienė29 Jan 2026
How can AI simplify compliance with international sanctions regimes?
In this article, we focus on the constantly evolving and highly complex legal landscape of EU sanctions imposed on third countries. We explore whether artificial intelligence (AI) can enable more efficient compliance, in particular by accelerating the assessment of whether a product transported along a specific route is subject to...
Digitalisation
Sanctions
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Overview of the 19th EU sanctions package against RussiaAušra Šablinskienė16 Nov 2025
Overview of the 19th EU sanctions package against Russia
On 23 October 2025, the Council adopted the 19th package of sanctions against Russia. The Council also introduced additional measures against Belarus to restrict its support for Russia’s war. Below is an overview of the changes requiring particular attention due to exemptions, derogations, and differing dates of entry into force...
Sanctions
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China’s export control system: overview and impact on EU traders
Sabine van Osenbrüggen11 Nov 2025
China’s export control system: overview and impact on EU traders
In recent years, China has established a comprehensive export control and sanctions regime that protects national security interests and influences international trade relations. This article provides a brief overview of the legal framework, controlled items, licensing procedures, sanction mechanisms, and current developments in China’s export controls as well as their...
Sanctions
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The EU revises the Common Position on military goodsSabine van Osenbrüggen10 Sep 2025
The EU revises the Common Position on military goods
Military goods are not just weapons or defence equipment - they can also include everyday items such as drones, hybrid vehicles, and vehicle parts if adapted for military use. Understanding these rules is essential for many stakeholders in international trade. This article outlines the new Council Decision (CFSP) 2025/779, adopted...
Sanctions
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Export control and software: what you need to knowSabine van Osenbrüggen30 Jun 2025
Export control and software: what you need to know
This is the fourth article in a series devoted to export controls, specifically addressing software as an item subject to these controls. In particular, what constitutes software? How can it be classified? What is the legal basis for this, from the EU and US perspectives? These questions are answered in...
Sanctions
Explainer
Administrative liability for sanctions evasion to be introduced in Latvia
Alisa Leskovica17 Jun 2025
Administrative liability for sanctions evasion to be introduced in Latvia
The article highlights Latvia’s recent efforts to strengthen the enforcement of EU sanctions against Russia and Belarus. It describes the latest amendments to the handling of sanctions violations. In particular, it explains changes to legal responsibilities and the shift towards administrative penalties in certain cases.
Sanctions
Country update
New to defence projects? Get export control rightSabine van Osenbrüggen09 Jun 2025
New to defence projects? Get export control right
The article provides a practical overview of export control requirements for companies involved in the supply of military goods and technologies. It outlines the relevant regulations, explains how military items are defined, and offers guidance on how businesses can manage compliance risks. If you are new to defence projects, this...
Sanctions
Explainer
Export control: are your products listed?Sabine van Osenbrüggen18 May 2025
Export control: are your products listed?
This is the third article in a series devoted to export control. The first covered the initial steps in export controls. The second explained how to get started. In this continuation of the export control series, we want to focus on your products, which your company produces or sells. We...
Sanctions
Explainer
Export control: where do we start?Sabine van Osenbrüggen14 Apr 2025
Export control: where do we start?
In this continuation of the export control series, we place ourselves in the position of a company expanding internationally and taking initial steps towards implementing export control procedures. In such instances, where no export control department or organisational structure yet exists, the question arises: who should assume responsibility for this...
Sanctions
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Export control – first stepsSabine van Osenbrüggen12 Mar 2025
Export control – first steps
Due to the many crises in the world and the associated need for security, the demand for export control is increasing once again. Furthermore, we see the states’ efforts in the EU increasingly investing in their defence. As a result, more and more companies are becoming suppliers to the defence...
Sanctions
Explainer
Don't let this happen to you! US export control law and re-export from the EUSabine van Osenbrüggen14 Jan 2025
Don't let this happen to you! US export control law and re-export from the EU
The American export control authority, the Bureau of Industry and Security, has published an updated version of “Don't let this happen to you!” - an introduction to the consequences of violating US export control law. As a European company, you may wonder why this should concern you. This is due...
Sanctions
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International sanctions and export controls: the latest challenges
International sanctions and export controls: the latest challenges
06 Dec 2024
International sanctions and export controls are critical tools for promoting global security and addressing geopolitical challenges. As these measures continue to evolve, businesses face increasing complexity in ensuring compliance while maintaining operational efficiency. This overview presents the latest trends and challenges in export controls and sanctions from a range of...
Sanctions
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Cyber-surveillance: new Commission guidelinesSabine van Osenbrüggen06 Nov 2024
Cyber-surveillance: new Commission guidelines
New Commission guidelines for cyber-surveillance exporters were published on 16 October 2024. The new guidelines aim to make EU controls “more effective and consistent across Member States”. The information provided by the Commission is not new but offers a clarification on how controls should be carried out by traders. They...
Sanctions
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