News & Analysis as of

Export Administration Regulations

Comprehensive Embargo on Sudan Lifted, Although Some Restrictions Remain

by K&L Gates LLP on

Effective October 12, the Trump administration revoked the U.S. embargo on Sudan in accordance with Executive Order 13761 (Jan. 13, 2017) and Executive Order 13804 (July 11, 2017). As a result of this action, Sudan and the...more

U.S. Lifts Sudan Sanctions

by Fox Rothschild LLP on

On October 12, 2017, the United States lifted its general commercial embargo on Sudan. Because Sudan has played a role in international terrorism, the U.S. has maintained a comprehensive embargo against Sudan since 1997....more

United States Eases Sudan Sanctions

by White & Case LLP on

After 20 years of comprehensive sanctions against Sudan, the US government has revoked most sanctions with respect to Sudan and the Government of Sudan effective October 12, 2017. As a result of this action, US persons1 are...more

Trump Administration Lifts U.S. Sanctions on Sudan; Important Limitations Remain

Based on certain State Department findings, effective October 12, 2017, long-standing U.S. sanctions on the Republic of Sudan administered by OFAC under the Sudan Sanctions Regulations will be terminated, and U.S. persons...more

Census Begins Review of Routed Export Reporting Requirement

• The U.S. Bureau of the Census has issued a notice requesting comments on the definition of “routed export transaction” and the responsibilities of parties in routed export transactions. Comments are due by December 5,...more

US Revokes Sudan Sanctions

On October 6, 2017, President Donald Trump and the U.S. Department of State announced the revocation of economic sanctions on Sudan, following the temporary lifting of sanctions on January 17, 2017. The announcement concluded...more

Recent ITAR Case Sends Important Message to Small/Midsized Government Contractors | Williams Mullen

by Williams Mullen on

A State Department ITAR enforcement case announced last week involving a supplier of military spare parts sends a valuable message to small and mid-sized government contractors of every type. The case involves Bright...more

Risks In The Common Practice Of Sending Technical Data Outside The U.S. — New Jersey Company Penalized $400,000

by Kelley Drye & Warren LLP on

Does your company source components or parts outside the U.S.? When doing so, you need to be careful about sending unlicensed export controlled technical data like drawings, blueprints and manufacturing instructions as part...more

ITAR For Government Contractors - Revised For Recent Amendments

by Williams Mullen on

Introduction. One of the most important areas of regulation for defense contractors is the International Traffic In Arms Regulations (ITAR). ITAR are the State Department controls that regulate the defense industry. Companies...more

Alert: Export Control Reminder: Semi-Annual Encryption Reporting Deadline 8/1/17

by Cooley LLP on

August 1, 2017, is the deadline for submitting semi-annual reports for certain ENC Restricted encryption items exported or re-exported between January 1 and June 30, 2017, pursuant to paragraphs (b)(2) and (b)(3)(iii) of...more

Boycott of Qatar by Arab Countries Can Implicate U.S. Anti-Boycott Rules

by Bryan Cave on

Saudi Arabia, Bahrain, and the United Arab Emirates have imposed a boycott on Qatar, allegedly because of remarks that appeared on the Qatar News Agency’s website where Qatar emir Sheikh Tamim bin Hamad Al Thani called Iran...more

Treasury Department Issues FAQ on Impact of Cuba Policy Shift

by Baker Donelson on

On June 16, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued a press release answering 12 "Frequently Asked Questions" ahead of President Trump's announcement of a revised U.S. policy...more

Mainbrace: June 2017 (No. 3)

by Blank Rome LLP on

Welcome to the summer 2017 edition of Mainbrace. To say we live in interesting times would be a serious understatement. We read headlines on a daily basis that challenge traditionally accepted notions of how governments...more

U.S. Treasury Releases FAQs Addressing Trump's Announcements on Changes to U.S.-Cuba Sanctions Regulations

by Holland & Knight LLP on

On the afternoon of June 16, 2017, shortly before President Donald Trump announced new changes to the U.S.-Cuba policy, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued 12 frequently asked...more

Update on Regulatory Compliance in the Global Health Care Industry

by Baker Ober Health Law on

A comprehensive understanding of the constantly evolving layers that make up federal anti-corruption statutes, sanctions regulations and export control restrictions is imperative for both the pharmaceutical and health care...more

The ZTE Case: U.S. Sanctions and Export Control Laws

by Benesch on

The settlement reached by China’s giant telecommunication company, ZTE Corporation (“ZTE”) with various U.S. government agencies, including U.S. Attorney’s Office, U.S. Department of Justice, U.S. Department of Commerce’s...more

Red Notice Newsletter - April 2017

ANTICORRUPTION DEVELOPMENTS – Former Magyar Telekom Executives Settle Bribery Charges – On April 24, 2017, the Securities and Exchange Commission (SEC) announced that two former executives of Magyar Telekom, a...more

Dealing with Violations in Export and Import Transactions

by Williams Mullen on

You are the general counsel or CEO of your company. Your compliance manager comes into your office and tells you that he/she may have discovered an export violation within the company. Or perhaps you have received a directed...more

Exporters Must Comply With Hong Kong Import and Export Controls

by BakerHostetler on

Beginning on April 19, 2017, individuals and companies planning to export to or re- export from Hong Kong will need to obtain certain paperwork prior to shipping. This new rule was published earlier in 2017, by the Department...more

Private Equity and the New Trump Administration: Your Top Ten Questions Answered

by Foley & Lardner LLP on

The election of President Trump contained some positive signs for Private Equity (PE) fund managers. These included potential lower corporate taxes, a ten-percent tax holiday for funds parked overseas, large infrastructure...more

U.S.-India Defense Cooperation Taken to the Next Level with Favorable Licensing Policy for Exports to India

On January 27, 2017, the Commerce Department’s Bureau of Industry and Security (BIS) recently made two significant changes to the Export Administration Regulations (EAR) concerning India that will facilitate the export of...more

New Documentary Requirements Issued for Hong Kong Exports and Reexports

by Morgan Lewis on

Effective April 19, 2017, US exporters intending to export certain controlled items to Hong Kong will need to obtain, prior to shipment, either a copy of a Hong Kong import license or a statement issued by the Hong Kong...more

"US Announces Record-Setting Penalties for Violations of Export Controls and Economic Sanctions"

On March 7, 2017, the United States announced that China’s Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd. and their respective affiliates (collectively, ZTE) had agreed to a record...more

Private Equity and the New Trump Administration: Your Top Ten Questions Answered

by Foley & Lardner LLP on

The election of President Trump contained more than a few positive signs for Private Equity (PE) firms. Promises of a lower corporate tax environment, a ten-percent tax holiday for funds parked overseas, large infrastructure...more

U.S. Department of Commerce Establishes Favorable Export Control Policies for India

by Ropes & Gray LLP on

On January 19, 2017, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule (the “Rule”) making two significant changes to U.S. export control policy with respect to India. First, the...more

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