In some cases dealing with certain persons or organisations in particular countries may be prohibited or restricted, or subject to prior approval by the authorities. In the EU, these rules are largely mandated by the European Commission in accordance with international agreements or treaty obligations (e.g. UN Sanctions), but in some cases, there may be additional EU or UK restrictions. Identifying all the particular restrictions and ensuring that those restrictions are not evaded can be difficult and time-consuming, as the legislation is not collated into a single source and interpretation can sometimes be tricky.
Importers who also re-export technologies from certain countries such as the US need also to be certain that they comply with all relevant extra-territorial restrictions, i.e. US denied party screening, and they should not assume that export to the UK or EU means that the products can be freely exported to non-EU countries or persons (e.g. particular persons or organisations on Cuba, Syria or Iran, which are sanctioned by the US). This is especially important for UK companies whose parent entities may be headquartered in the US. (See also Export Licensing).
4 Eyes Ltd has helped clients to identify and fully comply with their legal obligations, including compliance with extra-territorial provisions imposed by other countries. 4 Eyes Ltd also advises on trade defence in the event of enforcement action by HMRC.