"As I told Congress in July, my north star at BIS is to ensure that we are appropriately doing everything in our power to protect our national security and prevent sensitive technologies with military applications from being...more
11/9/2022
/ Bureau of Industry and Security (BIS) ,
China ,
ECCNs ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
Interim Final Rules (IFR) ,
Licenses ,
National Security ,
Popular ,
Semiconductors ,
Supply Chain ,
Technology Sector
As Russia’s invasion of Ukraine persists, with no end currently in sight, the United States continues to issue increasingly punishing economic sanctions and export controls targeting Russia, most recently aiming at the...more
5/17/2022
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Entities ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Professional Services Companies ,
Russia ,
Ukraine
Russia’s invasion into Ukraine in February 2022 has prompted the United States and its allies, including the United Kingdom, the European Union, and others, to issue substantial international trade restrictions such as...more
4/21/2022
/ Banks ,
Belarus Sanctions ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Transactions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Trade Relations ,
Trade Restrictions ,
UK ,
Ukraine
Following Russia’s recognition of breakaway regions in Ukraine and full-scale invasion of the country, authorities in the United States, United Kingdom, European Union, and across the globe imposed a sweeping array of trade...more
3/22/2022
/ Anti-Money Laundering ,
Anti-Terrorism Financing ,
Bank Secrecy Act ,
Belarus ,
Bureau of Industry and Security (BIS) ,
Convertible Virtual Currencies (CVCs) ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Economic Sanctions ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
FinCEN ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Patriot Act ,
Russia ,
SDN List ,
SWIFT ,
U.S. Treasury ,
UK ,
Ukraine
On February 21, 2022, Russian President Vladimir Putin unilaterally recognized the Luhansk and Donetsk regions in Eastern Ukraine (Covered Regions) as independent states. Thereafter, Mr. Putin authorized a full-scale invasion...more
3/3/2022
/ Banking Sector ,
Bureau of Industry and Security (BIS) ,
CAPTA List ,
Economic Sanctions ,
Export Controls ,
Exports ,
Financial Institutions ,
Financial Transactions ,
FinTech ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Sovereign Debt ,
SWIFT ,
Ukraine
The U.S. government on July 14, 2020, took two significant steps to address the evolving situation in Hong Kong. These were primarily in response to the enactment of the Law of the People's Republic of China on Safeguarding...more
7/22/2020
/ Blocking Sanctions ,
China ,
Economic Sanctions ,
Exceptions ,
Executive Orders ,
Export Controls ,
Foreign Financial Institutions (FFI) ,
Foreign Persons ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
Penalties ,
Preferential Trade Status ,
Termination Clauses ,
Trump Administration ,
US Trade Policies
The U.S. Department of Commerce, Bureau of Industry and Security (BIS) on April 28, 2020, published two final rules and a proposed rule that substantially tighten the controls in the Export Administration Regulations (EAR)....more
5/1/2020
/ Bureau of Industry and Security (BIS) ,
ECCNs ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Final Rules ,
General Licenses ,
Licensing Rules ,
Military End Use ,
National Security ,
U.S. Commerce Department
The Committee on Foreign Investment in the United States (CFIUS) published two final rules on January 17, 2019, to implement the Foreign Investment Risk Review Modernization Act (FIRRMA) enacted in August 2018. The first...more
2/13/2020
/ CFIUS ,
Code of Federal Regulations (CFR) ,
Covered Transactions ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Emerging Technologies ,
Emerging Technology Companies ,
Export Controls ,
Federal Pilot Programs ,
Final Rules ,
FIRRMA ,
FOCI ,
Foreign Investment ,
NAICS ,
National Security ,
New Rules ,
Real Estate Transactions
A recent federal appeals court decision addresses a familiar issue for many companies: When can a U.S. exporter be liable for a product that is re-exported to a sanctioned country, such as Iran? This update summarizes the...more
6/9/2017
/ Appeals ,
Corporate Liability ,
Distributors ,
Due Diligence ,
Electronics ,
Enforcement Actions ,
Export Controls ,
Exports ,
Iran ,
Iran Sanctions ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
United Arab Emirates (UAE)
President-elect Donald Trump has promised action that could drastically change the rules for U.S. importers and exporters, foreign shippers to the United States and service providers. Whether and how these promises translate...more
11/23/2016
/ China ,
Cross-Border Transactions ,
Export Controls ,
Free Trade Agreements ,
Imports ,
Mexico ,
NAFTA ,
Supply Chain ,
Trade Agreements ,
Trade Policy ,
Trade Relations ,
Trump Administration ,
WTO
During the same week that President Barack Obama announced sweeping changes in the diplomatic and trade relationships between the United States and Cuba, the president signed congressional legislation authorizing additional...more
1/7/2015
/ Banking Sector ,
Barack Obama ,
Corporate Counsel ,
Crimea ,
Cuba ,
Defense Sector ,
Drug Trafficking ,
Energy Sector ,
EU ,
European Commission ,
Executive Orders ,
Export Controls ,
Illegal Arms Dealers ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanctions ,
SDN List ,
Ukraine ,
US Trade Policies ,
Venezuela
On December 17, 2014, President Barack Obama announced sweeping changes in the diplomatic and trade relationships between the United States and Cuba. These changes, outlined below, will require time to implement; certain...more