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BIS Enhances Its Voluntary Self-Disclosure Process and Related Enforcement Guidance

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule (the “Rule”) regarding changes to the provisions of the Export Administration Regulations (the “EAR”) governing voluntary...more

U.S. Sanctions Russian Financial Infrastructure

On the eve of the 2024 Group of Seven (G7) Leaders’ Summit, the United States imposed new sanctions and export control measures against Russia further targeting sanctions evaders and, for the first time, the Russian...more

Multiple Governments Impose Joint Sanctions on Russia

On the second anniversary of the start of the war in Ukraine and in response to the death of activist Aleksey Navalny in a Russian prison, the United States, European Union, and United Kingdom, along with Australia and...more

The U.S. Department of Commerce Finalizes the CHIPS Act’s Guardrails to Curb National Security Risks

On September 25, 2023, the U.S. Department of Commerce (“Commerce”) issued the final rule (the “Final Rule”) regarding the use of funds offered under the CHIPS and Science Act (the “CHIPS Act”). The Final Rule...more

A New Risk Calculus: U.S. Department of Commerce Raises Stakes for Failing to Voluntarily Self-Disclose Potential Export Controls...

On April 18, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) Assistant Secretary for Export Enforcement, Matthew Axelrod, published a memorandum marking a shift in policy regarding voluntary...more

Russia Sanctions: Where Are We Now and What Could Be Next?

Since February 2022, the United States, United Kingdom, and European Union have imposed unprecedented economic sanctions on Russia and various Russian entities and individuals in response to the war in Ukraine. Actions have...more

Sanctions are “the New FCPA”: A Heightened Focus for DOJ Enforcement

At a New York City Bar Association event on April 27, Deputy Attorney General Lisa Monaco described economic sanctions as “the new FCPA.” Her characterization should put corporate compliance departments on notice. ...more

US, EU and UK Impose Unprecedented Sanctions Against Russia

Background As noted in our prior update, the United States, European Union and United Kingdom imposed a number of sanctions in connection with Russia’s recognition of the Donetsk and Luhansk regions of Ukraine. ...more

U.S. Readies Export Controls Against Russia

As concerns continue to build between Russia and the West over the situation in Ukraine, the United States, the European Union, and the United Kingdom are preparing measures that could be utilized if diplomacy is...more

The U.S. and EU Coordinate Sanctions Related to Navalny Poisoning and Sentencing: Biden Administration’s First Sanctions Against...

Executive Summary - On March 2, 2021, the Biden Administration, in a coordinated announcement by the U.S. Departments of Treasury, State, and Commerce, tightened export restrictions against Russia and imposed sanctions and...more

New Export Controls: Emerging Technologies

The U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) on October 5, 2020, published a final rule implementing new export controls on six categories of emerging technology. In doing so, the U.S. government...more

Potential Expansion of U.S. Export Controls: “Foundational” Technologies, Commodities and Software

The Department of Commerce, Bureau of Industry and Security (“BIS”), published an advance notice of proposed rulemaking (“the Notice”), on August 27, 2020, announcing the initiation of its review of foundational technologies...more

Department of Commerce Regulatory Changes: Eliminating Export Exemptions and Increasing Compliance Obligations to Gain Insight...

On April 28, 2020, the Commerce Department’s Bureau of Industry and Security (“BIS”) published two final rules and one proposed rule targeting national security controlled exports and reexports to China, Russia, and...more

COVID-19: International Trade Navigation

The outbreak of COVID-19 is impacting international trade as global markets deal with uncertain supply and companies and governments work to ensure personal safety while developing contingency plans for handling the virus. In...more

Cloud Solutions Allowed for Encrypted, Unclassified Defense Data

The State Department’s Directorate of Defense Trade Controls (“DDTC”) published an interim final rule on December 26, 2019, bringing the International Traffic in Arms Regulations’ (“ITAR”) treatment of encrypted electronic...more

More Than a Trade War: What the Huawei Arrest and Investigation Means to Your Business

On December 1, 2018, acting at the request of the United States, Canadian authorities arrested a senior officer of Huawei Technologies Co. (“Huawei”), the Chinese telecommunications equipment and consumer electronics device...more

New Government Regulation of Emerging Technology

The U.S. Government has instituted a major new initiative to regulate emerging technology, potentially including artificial intelligence, biotechnology, robotics, data analytics and many other types of emerging technology,...more

U.S. Moves Cautiously to Impose Mandated Sanctions Against Russia, While Congress Mulls Further Measures

On August 24, 2018, the U.S. Department of State announced a new but limited export licensing policy for defense and national security-sensitive goods and technology to Russia, effective August 27, 2018. The export licensing...more

Congress Finalizes CFIUS Reform as Final Passage Appears Imminent

After conferees from the U.S. House of Representatives (House) and U.S. Senate (Senate) reached agreement on the Foreign Investment Risk Review Modernization Act (FIRRMA), the House on Thursday, June 26, 2018, passed...more

House of Representatives Passes CFIUS Reform as the Trump Administration Reiterates its Support

The U.S. House of Representatives (the House) on June 26, 2018, passed legislation designed to reform and strengthen the authority of the Committee on Foreign Investment in the United States (CFIUS or the Committee), the...more

US Implements Changes to Cuba Sanctions

The U.S. Government this week announced changes to U.S. sanctions against Cuba to implement various policy changes announced by President Trump in July 2017 (for additional background, see our prior OnPoint from June 2017)....more

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