Question 1

How do trade sanctions differ from AML sanctions?

Accepted Answer

AML sanctions ("targeted financial sanctions") block dealings with named persons. Trade sanctions prohibit the export or re-export of specified goods, services or technology to specified destinations or end-users — even if no listed person is involved. Export controls overlap further by requiring...

Question 2

What is the US EAR and who does it apply to?

Accepted Answer

The Export Administration Regulations administered by the US Commerce Department's BIS. The EAR applies extraterritorially to any item "subject to the EAR" — including foreign-produced items containing more than de minimis US-origin content (10% or 25% depending on destination) and, under the For...

Question 3

What is the EU Dual-Use Regulation?

Accepted Answer

Regulation (EU) 2021/821 (recast). Establishes the EU export-control framework for dual-use items listed in Annex I. Requires authorisation for exports outside the EU, brokering, transit, and technical assistance. Annex IV items require licensing even for intra-EU transfers. Catch-all controls ap...

Question 4

What is the EU's CBAM and is it a sanctions regime?

Accepted Answer

The Carbon Border Adjustment Mechanism (Regulation (EU) 2023/956) is not a sanctions regime — it is a carbon-pricing mechanism on imports of carbon-intensive goods. It is mentioned here because it is often confused with sanctions in compliance budgets and because CBAM declarations and verificatio...

Question 5

What is forced-labour due diligence in EU law?

Accepted Answer

The Forced Labour Regulation (Regulation (EU) 2024/3015) prohibits placing or making available on the EU market, or exporting from the EU, products made with forced labour. The Corporate Sustainability Due Diligence Directive (CSDDD, Directive (EU) 2024/1760) imposes broader supply-chain human-ri...

Trade controls, export controls & dual-use goods