Export Administration Regulations

News & Analysis as of

U.S.-India Partnership: BIS Establishes Licensing Policy of General Approval, Expands Validated End-User Program

On January 19, 2017, the Department of Commerce’s Bureau of Industry and Security (BIS) published new regulations that establish a licensing policy of general approval for exports or reexports to, or transfers within, India...more

Freaky Friday – U.S. Unexpectedly Eases Sanctions on Sudan

- Virtually all U.S. sanctions on Sudan lifted effective January 17, 2017 - Sanctions could be permanently lifted in six months - There continue to be practical challenges to doing business in Sudan...more

"US Announces Tentative Lifting of Sudan Sanctions; OFAC Issues Guidance on Providing Sanctions Advice"

On January 13, 2017, President Obama and the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the interim lifting of sanctions on Sudan, with a path to a permanent revocation of sanctions in six...more

ITAR Guide for the Firearms Industry

The U.S. firearms industry is regulated under the National Firearms Act, Gun Control Act and other federal and state firearms laws. However there is another important area of regulation that applies to the firearms industry...more

Alert: Export Control Reminder: Encryption Reporting Deadline 2/1/17

The new year brings with it the reporting deadlines for exports of encryption items under the US Export Administration Regulations (“EAR”). February 1, 2017 is the deadline for submitting annual self-classification reports...more

"OFAC Eases Restrictions on the Export of Medical Devices to Iran"

On December 22, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced amendments to the general license (GL) that authorizes the export or re-export of certain medical devices to Iran....more

Smoother Sailing Ahead for Shippers After OFAC Clarifies Cuba Sanctions

On Friday, 6 January 2017, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) revised its Frequently Asked Questions (FAQs), adding five new FAQs (numbers 86-90) pertaining to vessel transactions with...more

White House Imposes Sanctions in Response to Malicious Russian Cyber Activity

On Dec. 29, 2016, in response to the Russian government’s “aggressive harassment of U.S. officials and cyber operations aimed at the U.S. election,” President Obama issued an Executive Order Taking Additional Steps to Address...more

United States Imposes Cybersecurity Sanctions on Russia

Key Points - - This action marks the first time sanctions have been imposed under the Cybersecurity Sanctions Program established on April 1, 2015, with the designation of nine entities and individuals. -...more

US Expands Cyber-Related Sanctions Executive Order and Designates Russian Parties

On December 29, 2016, President Obama issued a new Executive Order (EO) entitled "Taking Additional Steps to Address the National Emergency with Respect to Significant Malicious Cyber-Enabled Activities."...more

U.S. Antiboycott Compliance: New Federal List Published

Companies doing business in the Middle East take note: The Treasury Department recently published its quarterly list of countries that currently require participation or cooperation with an international boycott, such as the...more

Government Contracts Legislative and Regulatory Update - November 2016

We are pleased to send you the November edition of "Government Contracts Legislative and Regulatory Update," which offers a summary of the relevant changes that took place during the month of October. Highlights this month...more

Trade Compliance Issues in the New Administration, Part I: Export/Sanctions Laws

A change in administration will likely bring changes in export/sanctions laws and compliance obligations. This will include both last minute amendments by the outgoing administration and initiatives by the new President....more

Export Documentation Requirements Change Following EAR/ITAR Amendments

Export control documentation requirements are changing effective November 15, 2016. Specifically, the Department of Commerce’s Bureau of Industry and Security, and the Department of State’s Directorate of Defense Trade...more

Weekly Update Newsletter - November 2016

DEPARTMENT OF DEFENSE - Withholding of Unclassified Technical Data and Technology from Public Disclosure - The Department of Defense (“DOD”) Office of the Under Secretary of Defense for Acquisition, Technology, and...more

DoD’s Proposed Rule Would Create Additional Risk and Burdens for Contractors Handling Export-Controlled Information

The Proposed Rule creates a procedure for DoD to release unclassified technical data subject to EAR and ITAR to “qualified contractors,” which are defined to mean qualified U.S. and Canadian contractors. The Proposed Rule...more

"OFAC and BIS Implement Additional Amendments in Support of Cuba Policy Shift"

On October 14, 2016, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) announced further amendments to ease U.S. sanctions and...more

DOJ Publishes Guidance Encouraging Voluntary Self-Disclosures, Full Cooperation and Timely and Appropriate Remediation

On Oct. 2, 2016, the U.S. Department of Justice (DOJ), National Security Division (NSD) published Guidance setting forth its policy of encouraging business organizations to voluntarily self-disclose criminal violations of...more

US Further Liberalizes Cuba Sanctions and Export Controls

On October 14, 2016, the United States announced additional measures to liberalize Cuba sanctions and export controls, effective October 17, 2016. The new measures, which are summarized below, authorize additional...more

OFAC and BIS Changes to Cuba Sanctions Further Ease Trade and Travel Restrictions

On October 14, 2016, the Treasury Department’s Office of Foreign Assets Control (OFAC) and the Commerce Department’s Bureau of Industry and Security (BIS) published another round of amendments to the Cuban Assets Control...more

New Round of Cuba Sanctions Changes Expand Opportunities for Health Sector

Key Points - - OFAC’s latest changes expand opportunities for U.S. persons to engage in medical research with Cuban nationals, authorize U.S. persons to obtain FDA approval of Cuba-origin pharmaceuticals, and market...more

Obama’s Not Slowing Down On Cuba: New Steps Forward Open Doors (and Humidors!) for Collaboration

With fewer than 100 days left in office, President Obama is not slowing down on his efforts to normalize relations between the United States and Cuba. Today, several changes to the Cuban Assets Control Regulations (CACR) and...more

U.S. Authorities Amend Cuba Sanctions Regulations

On October 17, 2016, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and the Commerce Department’s Bureau of Industry and Security (BIS) issued new amendments to the Cuban Assets Control Regulations (31...more

U.S. Further Eases Embargo on Cuba

To further implement President Obama's December 2014 policy to support independent economic activity and improve communications and living conditions in Cuba, the U.S. Department of Commerce's Bureau of Industry and Security...more

U.S. Government Continues to Create New Opportunities for Trade with Cuba

Both the U.S. Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) have announced new amendments to the Cuban Assets Control Regulations (CACR) and Export...more

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