Nathalie Reid
Nathalie is a Senior Associate in Fieldfisher LLP's London-based Trade team. She specialises in the areas of sanctions and export controls and gives practical advice to businesses and industry bodies on trade and supply chain issues.
Practice Area
Panel
- Contributing Author
Qualified Year
- 2016
Experience
- MinterEllisonRuddWatts (2020 - 2024)
- Russell McVeagh (2016 - 2019)
Membership
- Asia New Zealand Foundation – Leadership network
Qualifications
- LLB (2015)
- BA (Public Policy and Chinese) (2015)
Education
- Victoria University of Wellington, New Zealand (2015)
6 Contributions by Nathalie Reid
PRACTICE NOTES
ECJU Compliance Visits under UK Export Controls: Scope, Preparation, Audit Process, Common Failings and Consequences
There are rigorous controls on the export, brokering and transhipment of ‘strategic’ goods, software and technology moving from or via the UK. This covers military kit and ‘dual-use’ items capable of serving both civil and defence purposes effectively. For guidance on whether these rules apply, see Practice Note Export controls—Requirement for an export licence. The Export Control Joint Unit (ECJU), a unit within the Department for Business and Trade, is responsible for issuing licences for controlled goods and for overseeing exporters’ compliance with the regime and the controls. Breaching the controls constitutes a criminal offence. HMRC and the Crown Prosecution Service (CPS) lead on investigations and prosecutions where parties fail to comply. For details on enforcing and prosecuting export control breaches, see Practice Note: The enforcement of export control breaches. That Practice Note reflects ECJU guidance on compliance visits, which can be found here.
Compliance with export controls
Businesses engaged in the export, brokering or transhipment of ‘strategic’ goods, software and technology should implement robust policies and procedures to ensure full compliance with the relevant regulations and controls in force. The ECJU publishes an ECJU—Compliance Code of Practice offering practical guidance to businesses on exporters’ responsibilities and obligations. Whilst the...
Corporate Crime
PRACTICE NOTES
UK trade sanctions enforcement under SAMLA 2018 and TASSCER 2024: HMRC and OTSI roles, civil and criminal powers, penalties, reporting and appeals
Trade sanctions
Trade sanctions are restrictions on the direct or indirect import and export of goods, non-financial services, or technology connected to, intended for, or used in or by a specified country, region, or person. The UK imposes sanctions to achieve multiple aims: advancing foreign policy and national security priorities, safeguarding international peace and security, and countering terrorism. UK sanctions regimes operate under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018) and extend across the whole UK, including Northern Ireland. As a result, UK trade sanctions apply to:
all individuals and businesses within the territory and territorial sea of the UK; and
all UK nationals or UK-incorporated businesses, wherever they are located worldwide
This Practice Note outlines how trade sanctions are enforced in the UK. For broader detail on trade sanctions, see the Practice Notes: Understanding the UK trade sanctions regime; Trade sanctions—offences; and Licences and exceptions in trade sanctions. For general sanctions guidance, see the Practice Note: International sanctions—an introduction. For the UK sanctions framework, see the Practice Notes: The UK sanctions framework under SAMLA 2018 and UK sanctions regimes currently in force...
Corporate Crime
PRACTICE NOTES
UK Trade Sanctions for Lawyers: Prohibitions, Licences, Compliance, Enforcement, Reporting and the Export Controls Distinction
What are trade sanctions?
Trade sanctions are restrictions that curb, whether directly or indirectly, the import or export of goods, non-financial services, or technology, where these relate to, or are intended for use in or by, a specified country, region, or individual.
The UK applies sanctions to fulfil several aims: supporting foreign policy and national security goals, safeguarding international peace and security, and countering terrorism.
These sanctioning regimes are established under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018) and cover the entirety of the UK, including Northern Ireland.
For further information on SAMLA 2018, see Practice Notes: The UK sanctions framework under SAMLA 2018 and UK sanctions regimes currently in force...
Corporate Crime
PRACTICE NOTES
UK trade sanctions offences under SAMLA 2018: corporate liability, licences, defences, enforcement and penalties
The Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018)
Established after Brexit, SAMLA 2018 sets out a UK‑centric system for putting sanctions in place and policing them domestically as well. The core UK sanctions regimes have been brought in via secondary legislation, and SAMLA 2018 permits regulations to be made covering the enforcement of any ban or obligation created by a regulation. See Practice Notes: The UK sanctions framework under SAMLA 2018 and UK sanctions regimes currently in force. Under sanctions regulations, SAMLA 2018 authorises the imposition of trade sanctions. Such trade measures curb the direct or indirect import or export of goods, non‑financial services, or technology connected to, intended for use in, or used in or by, a specified country, region, or person. Note that trade sanctions intersect with export controls but are not the same. See Practice Note: Understanding the UK trade sanctions regime—What are trade sanctions? Each distinct sanctions regime may include trade‑related provisions, identifying the goods and/or services that are barred. Regulations made pursuant to SAMLA 2018 establish criminal offences to enforce prohibitions and requirements, and to stop the evasion of trade sanctions. Regulations can also set out exceptions and licences. See Practice Note: Licences and...
Corporate Crime
PRACTICE NOTES
UK Trade Sanctions: A Practitioner's Guide to Exceptions, General and Specific Licences (OTSI, Import Licensing Branch, ECJU) and Offences
Trade sanctions
Trade sanctions place restrictions on the following:
the import, export, transfer, movement, supply, and procurement of goods and technology
the delivery and sourcing of services connected to goods and technology
the supply and obtaining of specified non-financial services
This Practice Note outlines exceptions and licences permitting activities otherwise prohibited by trade sanctions. For general guidance on trade sanctions, see Practice Notes: Understanding the UK trade sanctions regime; Trade sanctions—offences; and The enforcement of trade sanctions breaches in the UK.
This Practice Note concerns trade sanctions only. For information on licences and exemptions in financial sanctions, see Practice Note: Licences and exemptions in financial sanctions.
For background on the UK’s domestic sanctions framework, governed by the Sanctions and Anti-money Laundering Act 2018 (SAMLA 2018) and regulations made under it, see Practice Notes: The UK sanctions framework under SAMLA 2018 and International sanctions—an introduction.
Regulations containing trade sanctions
Various sanctions regulations made under SAMLA 2018 include trade sanctions. Practitioners should always consult the specific statutory instrument for the relevant regime to confirm whether trade sanctions are imposed...
Corporate Crime
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