Export Administration Regulations

News & Analysis as of

White Collar Enforcement and the New Trump Administration: Your Top Ten Questions Answered

Enforcement activity under the Obama administration often made headlines for the eye-popping level of fines, with the Foreign Corrupt Practices Act (FCPA), Anti-Money Laundering (AML) regulations, and economic sanctions...more

OFAC Eases Certain Sanctions Involving Russia’s FSB; BIS Licensing Still Required

On February 2, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Cyber-related General License (GL) 1, a general license that authorizes certain transactions with Russia’s Federal...more

Demonstration of Compliance with Hong Kong Law Now A Must for U.S. Exporters to Hong Kong

The Commerce Department’s Bureau for Industry and Security (BIS) has issued a new rule that requires exporters to Hong Kong of items subject to certain controls under the Export Administration Regulations (EAR) to obtain...more

DDTC and BIS Request Comments on Additional Proposals for Category XII and Infrared Detection Items

Key Points - - DDTC and BIS are requesting additional comments from companies affected by the recent Category XII ECR changes that went into effect on December 31, 2016. - The notices of inquiry generally...more

Recent OFAC Amendments - Sudan & Iran

Recent OFAC Amendments Make Significant Changes to Sudanese Sanctions Regulations, Expand General Licenses for Agricultural Commodities, Medicine and Medical Devices under the Iran Transactions and Sanctions Regulations, and...more

Obama Administration Announces Relief of Sudan Sanctions Measures

On January 13, 2017, President Barack Obama signed an Executive Order (the “Sudan Executive Order”) that will effectively revoke, after six months (i.e., on July 12, 2017), the U.S. trade embargo against Sudan, provided the...more

OFAC Issues General License Authorizing Most Transactions with Sudan

On January 13, 2017, President Obama signed Executive Order 13761 (“E.O. 13761”), “Recognizing Positive Actions by the Government of Sudan and Providing for the Revocation of Certain Sudan-Related Sanctions.” Effective July...more

New Requirements for Exports and Reexports to and from Hong Kong: BIS Requires Exporters and Reexporters to Confirm Compliance...

On January 19, 2017, the Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule increasing compliance requirements associated with the export and reexport of items controlled under the EAR to...more

Federal Trade Commission Revises Hart-Scott-Rodino Thresholds

As it does every year at this time, the Federal Trade Commission (FTC) has issued revised Hart-Scott-Rodino Act (HSR) jurisdictional thresholds for the upcoming year. The FTC is required by law to revise the filing thresholds...more

Significant Sanctions and Export Control Amendments Regarding Hong Kong and Sudan Are Announced in Final Days of Obama...

In the past week, there has been an easing of sanctions against Sudan, and requirements have been added to the export control regulations regarding exports and reexports of certain commodities, technology, and software to...more

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

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