Exports Export Controls

News & Analysis as of

President Trump, the Ex-Im Bank and Aircraft Finance

The Export-Import Bank of the United States has been embroiled in a considerable amount of political controversy in recent years. Created in 1934 by a presidential executive order to finance and facilitate the export of U.S....more

Obama Administration Issues Changes to Iran Sanctions Regulations That Benefit Exporters of Medicine, Medical Devices and...

On December 23, 2016, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a number of changes to the Iranian Transactions and Sanctions Regulations (“ITSR,” 31 C.F.R. Part 560) that expanded the...more

United States Issues Executive Order, General License Easing Sudan Sanctions

On January 13, 2017, President Obama signed an Executive Order entitled "Recognizing Positive Actions by the Government of Sudan and Providing for the Revocation of Certain Sudan-Related Sanctions."...more

The Obama Administration Eases Sanctions Against Sudan

On January 13, 2017, the White House, the U.S. Department of Treasury ’s Office of Foreign Assets Control (OFAC) , and the U.S. Department of Commerce ’s Bureau of Industry and Security (BIS) announced a host of policy...more

Managing global telecom supply chains – What telecommunications companies need to know about trade control laws

Maintaining a global supply chain brings its share of commercial, financial, and regulatory risks. Increasingly, telecommunications companies with global operations and suppliers are finding that U.S. trade control laws...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

2017 Key Trade Issues: U.S. Embargoes and Economic Sanctions on Iran, Russia, and Cuba

U.S. embargoes and economic sanctions on countries such as Iran, Russia and Cuba were discussed at length by both candidates during the 2016 Presidential campaign, and President-Elect Trump has stated that he intended to...more

One Step Up: U.S. Export Controls for Pharma/Device Companies

2016 was an active year for U.S. export control developments impacting U.S. pharma/device companies. We expect 2017 also to be busy, especially with the upcoming change in Administrations. This article briefly will review for...more

Companies Face New Process in Disclosures of Potential Export Violations

Companies opting to file voluntary disclosures of potential export violations with the State Department’s Directorate of Defense Trade Controls (DDTC) will soon be required to utilize a new process for submitting their...more

Make Sure You Address Compliance with Export Controls

Compliance officers have to avoid professional myopia. The focus of compliance these days has been on anti-corruption, antitrust, and AML, depending on your company’s industry. They fit nicely together under an...more

New Format for Filing CJ Requests via New Defense Export Control and Compliance System (DECCS)

As the export agencies still strive to implement one system for export licensing and compliance, DDTC has come one step closer by creating a new on-line process for filing CJ requests. As of November 16 at 5 pm, DDTC will no...more

Continuation of ZTE General License Until February 27, 2017

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) is again extending the general license for exports, reexports (shipments from one foreign country to another foreign country), and in-country transfers...more

November 15, 2016 Implementation Date for BIS and DDTC Harmonized Destination Control Statements

As part of the President's Export Control Reform (E CR) initiative, the Department of Commerce, Bureau of Industry and Security (BIS) and the Department of State, Directorate of Defense Trade Controls (DDTC) issued a final...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

Update on Life Sciences Exports to Iran and Sudan

On September 28, the Office of Foreign Assets Control (OFAC) at the U.S. Department of the Treasury issued its Biennial Report of Licensing Activities Pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000,...more

Bob Dylan Wins the Nobel Prize – Cuba Slowly Opening for Business (under the FCPA)

Bob Dylan won the Nobel Prize for literature. Those were words I never thought I would see in the same sentence, let alone write in the same sentence. Yet here we are, the first rock and roller to win the Nobel Prize. While...more

US Implements Regulation Changes for Encryption Products, Software and Technology

On September 20, 2016, the Bureau of Industry and Security (BIS) of the U.S. Commerce Department amended the Export Administration Regulations (EAR) and the list of goods, software and technology that are controlled under the...more

Burma Sanctions Regulations to be Terminated

On September 14, 2016, the President announced his intention to terminate the national emergency with respect to Burma, the effect of which will be to end the current U.S. sanctions program against that country as overseen by...more

Every U.S. Life Sciences Company Needs an Export Control Compliance Program (No, Really….)

Two recent settlements by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) confirm that every U.S. life sciences company engaging in exports should have an effective U.S. export control compliance...more

Redefining U.S. Export Controls: Takeaways from Key Changes Effective September 1st

On September 1, 2016 new rules previously published by the U.S. Department of Commerce, Bureau of Industry and Security (BIS)1 and the U.S. Department of State, Directorate of Defense Trade Controls (DDTC)2 will become...more

Final Rules Affecting Definitions of Export and Fundamental Research Take Effect

Amended definitions under the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR) became effective today, Sept. 1, 2016. Although there are no significant changes to the scope or...more

Anti-Corruption, Sanctions and Export and Import Risks

Forgive me for overusing the term “convergence” but when the shoe fits, I say “wear it.” If you are managing corporate risks and responsible for securing export licenses, ensuring that you are complying with OFAC sanctions...more

With the New Definitions Rules from Commerce and State, Do You Need to Change Your Export Compliance Program? (IRB No. 555)

The long-awaited definitions rules have finally arrived as part of Export Control Reform. But wait, they’re not all there—the definitions, that is. While Commerce addressed essentially all of the items included in its last...more

Alert: US Government Issues Administrative Subpoena to Huawei Technologies

According to recent news reports, the US Commerce Department's Bureau of Industry and Security ("BIS") issued a subpoena in April to Huawei Technologies Co. ("Huawei"), one of the world's largest telecommunications equipment...more

Contracting Globally - Part 1: Export Administration Regulations

The potential for government contractors to grow and become successful outside of the U.S. is tremendous and should not be overlooked by small businesses. The world outside our borders is a critical marketplace that should be...more

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