Export Controls

News & Analysis as of

US Implements Additional Measures to Liberalize Cuba Sanctions

On September 21, 2015, the United States further amended existing regulations to implement the changes announced by President Obama on December 17, 2014 liberalizing US sanctions and export controls targeting Cuba. As a...more

"OFAC and BIS Further Ease Cuba Restrictions"

On September 21, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) amended their respective Cuba regulations to...more

Colombian Companies Face New Compliance Challenges as Nation Ascends to World Economic Stage

When OFAC added Colombian sports franchise Envigado Fútbol Club to its sanctions list in June 2014, the news conjured up echoes of past dark days of “narco fútbol,” when the tentacles of organized crime touched the country’s...more

U.S. Government Takes Steps to Further Ease Restrictions on Cuba

U.S. Commerce and Treasury Department measures intended to further ease existing export and sanctions restrictions regarding Cuba took effect on September 21, 2015. These amendments to the Cuban Assets Control Regulations...more

You Want to Export to Cuba? Get Ready, But You Probably Can’t Quite Yet.

New rules came out on September 21, 2015 from both the Commerce and Treasury Departments. Although for the most part these changes only slightly broaden or clarify pre-existing exceptions to the embargo against Cuba, they...more

US revises Cuba sanctions regulations to further normalize trade with Cuba

On September 18, 2015, the US Department of Treasury and US Department of Commerce released significant revisions to the US embargo on Cuba, as set out in the Cuban Assets Control Regulations (CACR) and the Export...more

Legislation Allowing the Export of U.S. Crude Oil Advances in Congress, EIA Report Lauded as Support

Modification of the U.S. policy restricting exports of domestic crude oil has been at the forefront of energy policy discussion due to the country’s recent emergence as a leader in oil and natural gas production. ...more

Extension of EU Economic Sanctions and Trade Measures Targeting Russia

The Council of the European Union (EU) has extended the existing EU framework of trade and economic sanctions targeting specific Russian individuals and entities, and certain sectors of the Russian economy until 15 March...more

Push to lift ban on crude oil exports gains momentum in Congress

Proponents of lifting the US ban on crude oil exports have made significant progress in recent weeks. The House Energy and Commerce Committee approved a bill today to lift the decades-long statutory prohibition. This follows...more

Proposed Amendments Provide Data Security Standard Under ITAR and EAR

The Commerce and State Departments have issued long-awaited proposed regulations that provide data security standards for use in the transmission and storage of ITAR-controlled and EAR-controlled electronic data. If enacted...more

International Trade Alert: Iranian sanctions and a new Office of Financial Sanctions Implementation

Under the terms of the agreement, EU and US sanctions relief will be provided through the suspension and eventual termination of sanctions measures, beginning only if and when the International Atomic Energy Agency verifies...more

D.C. Circuit to Decide Scope of Judges’ Authority in Approval Process for Deferred Prosecution Agreements

A federal judge exceeded his authority when he rejected a deferred prosecution agreement (DPA) entered into earlier this year by the U.S. Department of Justice (DOJ) and a Dutch aerospace company, the DOJ and company will...more

Iran Nuclear Agreement – Mixed Bag for U.S. Exporters

The Iran Nuclear Agreement provides certain opportunities for U.S. firms, but these are not as significant as many U.S. business executives had hoped. The following are highlights of the most important provisions of the Iran...more

Russia Sanctions Update

On September 2, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule amending the Export Administration Regulations (EAR) by adding 29 parties to its Entity List, a...more

Pardon the “Intrusion” – Cybersecurity Worries Scuttle Wassenaar Changes

Companies concerned about their cybersecurity posture can breathe a small sigh of relief, as the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) recently announced it was scrapping plans to implement new...more

U.S. State Department Targets Russian, Iranian Firms in Sanctions Move Against WMD and Missile Proliferation

The U.S. Department of State imposed sanctions on September 2, 2015, against 23 companies around the world for involvement in the transfer or purchase to or from Iran, North Korea or Syria of goods, services or technology...more

State Sponsor of Terrorism Amendment Made to EAR Regarding Cuba

Amendment triggers change in EAR de minimis level for controlled US-origin content in foreign made products. On April 14, US President Barack Obama submitted to Congress the statutorily required report indicating the...more

Think Big Picture – minimize corporate export compliance risks while protecting your information security

Recently I have attended several cyber security conferences. What I have learned about protecting information has changed how I view export controls. Senior management and board members should think about the big picture as...more

Red Notice Newsletter - August 2015

Welcome to the August 2015 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month on the anticorruption front, the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange...more

U.S. Government Approves Crude Oil Swaps with Mexico While Congress Considers Repealing the Underlying Export Restrictions

On August 14, 2015, the U.S. Department of Commerce’s, Bureau of Industry and Security (BIS) indicated that it would approve a number of export license applications permitting parties in the United States to swap crude oil...more

U.S. Department of Commerce Places Severe Export Restrictions on Russian Deepwater Oil and Gas Field

On August 7, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule adding the Yuzhno-Kirinskoye Field, a Russian oil and gas field located in the Sea of Okhotsk, to its Entity...more

UK Export Licensing Trends

The Export Control Organisation (ECO) has released its latest set of data on export licensing. For the first time, this has been produced to be compliant with the UK Statistics Authority’s code of practice for official...more

The Baby and the Bathwater: The Department of Commerce’s Bureau of Industry and Security (BIS) Intrusion and Surveillance Software...

If you are not aware, please take note that the July 20, 2015 deadline is fast approaching for comments to the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) proposed rule on the export control of certain...more

EU Customs Practice Group - June 2015

EU CUSTOMS POLICY - Union Customs Code Developments It has become clear that there are further delays in finalising the draft Union Customs Code (UCC) Implementing and Delegated Acts within the Commission, in light of a...more

Top 10 Things to Know About the Easing of Sanctions Under the Iran Nuclear Agreement

The Iran sanctions landscape is poised to change in early 2016, but US persons and US companies will see far fewer opportunities than their European counterparts. On July 14, 2015, the P5+1 countries (the United...more

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