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Sanctions Update: is the US 'maximum pressure' approach to sanctions (including against Iran) set to thaw?

In recent weeks, rumours have started to circulate that President Biden's administration is set to depart from the US government's current approach to the use of sanctions. While the administration's review of US sanctions policy remains ongoing, details of a new softer approach, which is expected to be formally outlined when the review is published at the end of the summer, were described by a number of current and former administration officials in a series of high-level meetings held in the US Congress.

Anti-bribery update: SFO enters into £103m DPA with Amec Foster Wheeler

On 1 July, which marks the 10th anniversary of the UK's Bribery Act coming into force, the Serious Fraud Office ("SFO") secured court approval for a Deferred Prosecution Agreement ("DPA") with Amec Foster Wheeler Energy Limited ("AFWEL"). This latest DPA concludes yet another significant multi-year corruption probe and highlights the importance of continued ABC compliance measures for multinational organisations.

The Integrated Review 2021: new UK sanctions and money laundering regimes to be introduced

On 16 March 2021, the UK Government published a delayed integrated review of security, defence, development and foreign policy, setting out in general terms the UK's approach to national security and international policy over the next five years (the "Integrated Review").

Business & Human Rights Update: UK Government announces further supply chain restrictions

The evidence outlined by the UK Government includes allegations of forced sterilisation, extra-judicial detention and forced labour. The proposals are intended to "send a clear message that these violations of human rights are unacceptable, and to safeguard UK businesses and public bodies from any involvement or linkage with them".

Exporting Dual-Use items to EU Member States from the UK: The new rules

On 16 October 2020, the UK’s Export Control Joint Unit ("ECJU") issued a timely reminder to UK businesses that an Open General Export Licence ("OGEL") will be required where a business is exporting dual-use items, as set out in Annex 1 of EU Regulation 428/2009 (the "Dual-use Regulations"), to any EU member state, and the Channel Islands, from 1 January 2021.

EU Conflict Minerals Regulation

The EU passed a Regulation on Conflict Minerals ("the Regulation") back in 2017 and its requirements will finally begin to apply to importers of covered minerals as of 1 January 2021. Conflict minerals – usually "the 3Ts" (tantalum, tin, and tungsten) and gold ("3TG") are crucial in the components of many consumer electronic products and have applications in aerospace, automotive, medical and other sectors.

CFIUS Update – US Treasury Department modifies filing requirements for critical technologies

Following a consultation undertaken by the US Treasury Department, a new rule will come in to force on 15 October 2020 altering the current mandatory Committee on Foreign Investment in the United States ("CFIUS") filing requirements. The amendment relates specifically to foreign direct investments ("FDI") into US businesses with a 'critical technology' focus.

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