On 21 September, Reed Smith reported on new FAQ on 19 September, which reverse the controversial expansion of restrictions imposed on certain coal, fertiliser and other Russian-origin goods on 10 August.  These FAQ clarify that restrictions on certain fertiliser and coal products (among others) do not include a ban on their transfer to third countries, and associated insurance and brokering arrangements.  It says that the EU has clarified that certain goods are now permitted to be transferred (including transported) to non-EU countries to mitigate food and energy insecurity.  The EU has also amended a FAQ to clarify that relevant services (such as financial assistance including brokering or insurance) tied to the transfer of the above-listed goods to third countries via EU operators or the EU territory are now permitted.

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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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