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On 4 January 2022, the new UK foreign investment review regime under the National Security and Investment Act came into force, completing the overhaul of the UK’s foreign investment rules and commencing operation of a standalone foreign investment screening regime for the first time in the UK.

In December 2021, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued four General Licenses (“GLs”) (GLs 16, 17, 18, and 19), published seven new Frequently Asked Questions (“FAQs”) (FAQs 949, 950, 951, 952, 953, 954, and 955), and amended three FAQs (FAQs 929, 930, and 931), which address primarily authorized humanitarian activities related to Afghanistan OFAC also issued a Fact Sheet titled “Provision of Humanitarian Assistance to Afghanistan and Support for the Afghan People” to provide further guidance on the scope of US sanctions and authorized humanitarian activities in relation to Afghanistan. Key points are summarized below.

On 21 December 2021, the Court of Justice of the European Union issued its judgment in Bank Melli Iran (C-124/20). The judgment relates to the application of the EU Blocking Regulation (Regulation (EC) No 2271/96). The Blocking Regulation prohibits EU businesses from complying with certain extraterritorial US sanctions targeting Iran and Cuba. In many Member States, breaches of the Blocking Regulation can expose you to criminal penalties, albeit that enforcement has been very minimal to-date.

On 15 December 2021, the European Parliament adopted a resolution on the challenges and prospects for multilateral weapons of mass destruction arms control and disarmament regimes. The resolution calls for the EU to play a strong role, and for member states to show continuous support, in all major disarmament treaties and non-proliferation regimes.