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Closing the Loophole: Biden Administration Takes Action Against De Minimis Imports from China

On September 12, 2024, the Biden Administration announced a number of new trade-related measures related to imports of Chinese-manufactured goods. This announcement comes as the latest action in the Biden Administration’s...more

BIS Imposes New Export Controls on Quantum, Semiconductor and Additive Manufacturing Technologies

On September 5, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule imposing significant new export controls on quantum computing, cryocooling systems, semiconductor...more

USTR Calls for Stakeholder Comments Following the Report on the Four-Year Review of the Section 301 Tariffs

On May 22, USTR followed up the recommendations in its March 14 report with specific proposals for increases in Section 301 tariffs. There will be an exclusion process allowing interested parties to request temporary...more

USTR Issues Long Awaited Report on the 4-Year Review of the Section 301 Tariffs

On May 14, 2024, the U.S. Trade Representative (“USTR”) published the Four-Year Review of Actions Taken in the Section 301 Investigation (“Report”), which addresses the four-year review of China-related tariffs under Section...more

State Department Proposes Exempting Australia, UK from Certain Defense Related Export Controls

On April 30, 2024, the Department of State proposed an amendment to the International Traffic in Arms Regulations (ITAR) intended to facilitate exports of defense articles, the performance of defense services, and brokering...more

Further Enhancing Australia, United Kingdom, United States (AUKUS) Trilateral Security Partnership through Export Controls

On April 19, 2024, the Department of Commerce Bureau of Industry and Security (BIS) issued an interim final rule reducing export control licensing requirements for Australia and the United Kingdom (UK) as a means to further...more

Correcting and Clarifying Export Controls Issued on Advanced Computing and Semiconductor Manufacturing Items

On March 29, 2024, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) issued an interim final rule (“2024 IFR”) clarifying and correcting its October 2023 interim final rules on advanced...more

U.S. Increases Export Restrictions Against Nicaragua

The U.S. Department of Commerce amended the Export Administration Regulations (EAR), effective March 15, 2024, to move Nicaragua from Country Group B to Country Group D, and added it to the list of countries subject to the...more

DoD Publishes Final Rule Implementing Executive Order 14005

The rule conforms applicable DFARS clauses to the final FAR rule that was published on March 7, 2022. Contractors must comply with increasing U.S. and qualifying country content thresholds for manufactured end products—65...more

BIS Issues Additional Enhancements to Voluntary Self-Disclosure Process

Takeaways: On January 16, 2024, the Bureau of Industry and Security (“BIS”) Office of Export Enforcement (“OEE”) announced several updates to its Voluntary Self-Disclosure (VSD) process aimed at enhancing the program’s...more

Closing the Loopholes: Additional Export Controls Issued on Advanced Computing and Semiconductor Manufacturing Items

On November 6, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) held a public briefing to address industry questions concerning the latest export controls on advanced computing and semiconductor...more

Expansion of Global Capability Centers Requires Anticorruption Compliance Planning

Companies looking to set up global capability centers in India should take steps at the outset to assure compliance with applicable anti-bribery and anti-corruption laws and standards. The FCPA prohibits bribing or...more

OMB Finalizes “Build America, Buy America” Domestic Content Guidance

The Build America, Buy America Act generally requires that non-federal government infrastructure projects that benefit from federal government funding impose requirements for the use of domestic iron and steel and...more

Proposed Rule Increases Buy American Act Content Thresholds for DoD Contracts

The Department of Defense has proposed an amendment to the Defense Federal Acquisition Regulation Supplement to align with the Federal Acquisition Regulatory Council’s update to the Federal Acquisition Regulation in...more

IRS, Department of Treasury Release Guidance on Domestic Content Rules for Energy Projects

The Guidance sets out the requirements for using domestic steel, iron and manufactured products in order for a project to be eligible for the domestic content bonus credit amount. Projects that meet the domestic content...more

DFARS Proposed Export Controls Rule Would Require Supplying DCMA with Copy of Relevant Export Authorizations

On March 22, 2023, the Department of Defense (DoD) published a proposed rule to amend Defense Federal Acquisition Regulation Supplement (DFARS) clause 252.225-7048. This amendment would implement an additional export control...more

4/11/2023  /  DCMA , DFARS , Exports

Additional Sanctions and Export Control Restrictions Imposed on One-Year Anniversary of Russia-Ukraine Conflict

On February 24, 2023, the one-year anniversary of the Russia-Ukraine conflict, the United States released extensive new measures designed to impose additional sanctions on Russia for its aggression against Ukraine. These new...more

Russia Sanctions Year in Review: Impact on Aviation Sector

This post marks the third entry in our Year-in-Review series. For prior posts, click here. Many of the first measures that the United States, European Union and United Kingdom collectively took against Russia in 2022 related...more

OMB Proposes Revisions to Guidance Supporting the Implementation of IIJA’s Build America, Buy America Act Provisions

Funding provided under the Infrastructure Investment and Jobs Act (IIJA) is conditioned on complying with domestic content requirements. The Office of Management and Budget (OMB) has proposed new regulations to implement...more

Russia Sanctions Year in Review: Impact on Energy Sector

This post marks the second entry in our Year-in-Review series. For prior posts, click here. Few sectors have been more affected by the sanctions on Russia than the energy industry....more

Russia Sanctions Year in Review: Impact on Financial Services Sector

On February 24, 2022, the United States (U.S.), European Union (EU), United Kingdom (UK), and other countries issued a barrage of sanctions against the Russian financial sector, cutting off many major banks from the global...more

Implementing the Russian Oil Price Cap – Most Recent U.S. Guidance

On December 5, 2022, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $60 per barrel price cap on maritime transfers of Russian-origin crude oil. The final cap level is being implemented...more

Preparing for the Oil Price Cap: What We Know So Far

Various reports indicate that the Group of Seven nations (G7) will announce its initial capped price for Russian-origin crude oil transported by maritime means (“seaborne”) this week. The cap will come into effect on December...more

11/28/2022  /  Crude Oil , Economic Sanctions , G7 , Oil & Gas , Russia

Commerce Issues Guidance on Recent Advanced Computing and Semiconductor Manufacturing Controls for China

On October 28, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued guidance on its October 7, 2022 interim final rule (Rule) that imposed new export controls on certain advanced computing...more

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