On April 5, 2019, the World Trade Organization released its Panel report on “Russia – Measures Concerning Traffic in Transit,” in which it reviewed for the first time the national security exception contained in Article XXI of the General Agreement on Tariffs and Trade 1994 (GATT). In the dispute, Ukraine challenged the legality of Russian measures restricting the transit of the Ukrainian goods meant for Central Asia through Russian territory, while Russia argued that the transit restrictions are justified under the national security exception as “necessary for the protection of its essential security interests” and that the Panel lacks jurisdiction to address the matter. The Panel rejected Russia’s claim on jurisdiction and determined that it had jurisdiction to interpret the clause and review the matter. The Panel then defined an emergency in international relations as “a situation of armed conflict, or of latent armed conflict, or of heightened tension or crisis, or of general instability engulfing or surrounding a state,” and concluded that the situation between Ukraine and Russia had constituted an emergency in international relations since 2014. The Panel decided that Russia had established that its measures were taken during an “emergency in international relations” and were therefore covered by Article XXI of the GATT.