On January 13, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an Interim Final Rule (IFR), establishing new export controls targeting advanced artificial intelligence (AI) chips and model...more
1/24/2025
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
Data Centers ,
Data Security ,
Export Administration Regulations (EAR) ,
Export Controls ,
Intellectual Property Protection ,
Machine Learning ,
National Security ,
Regulatory Requirements ,
Technology Sector
Broad Tariff Increases Could Reshape Global Trade: The aggressive use of tariffs could create significant trade disruptions for businesses dependent on global supply chains, and pair novel use of authorities with existing...more
11/25/2024
/ Artificial Intelligence ,
CFIUS ,
China ,
Cuba ,
Dual Use Goods ,
Economic Sanctions ,
Export Controls ,
FIRRMA ,
Forced Labor ,
Foreign Investment ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Iran ,
Jurisdiction ,
Middle East ,
Popular ,
Russia ,
Section 301 ,
Semiconductors ,
Supply Chain ,
Tariffs ,
Trade Act of 1974 ,
Trade Expansion Act of 1962 ,
United States-Mexico-Canada Agreement (USMCA) ,
USTR ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Venezuela
New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons.
Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more
3/27/2024
/ Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Transactions ,
Foreign Corporations ,
Foreign Direct Product Rule ,
Foreign Jurisdictions ,
Know Your Customers ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Risk Assessment ,
Risk Mitigation ,
Trade Relations ,
U.S. Commerce Department ,
U.S. Treasury
How should companies think about DOJ, BIS and OFAC voluntary disclosure in the wake of the DOJ’s massive investment in sanctions and export control enforcement?
The DOJ, BIS and OFAC released a joint compliance note...more
8/4/2023
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Embargo ,
Enforcement ,
Export Controls ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Self-Disclosure Requirements ,
White-Collar Exemptions
In a new enforcement action against GM, the Department of Justice (DOJ) Civil Rights Division emphasizes that employers subject to export control obligations must still comply with federal laws against discrimination on the...more
5/23/2023
/ Anti-Discrimination Policies ,
Civil Monetary Penalty ,
Civil Rights Act ,
Compliance ,
Department of Energy (DOE) ,
Department of Justice (DOJ) ,
E-Verify ,
Employment Eligibility Verification ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Form I-9 ,
Immigration and Nationality Act ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Title VII
This post marks the third entry in our Year-in-Review series. For prior posts, click here. Many of the first measures that the United States, European Union and United Kingdom collectively took against Russia in 2022 related...more
This post marks the second entry in our Year-in-Review series. For prior posts, click here. Few sectors have been more affected by the sanctions on Russia than the energy industry....more
On February 24, 2022, the United States (U.S.), European Union (EU), United Kingdom (UK), and other countries issued a barrage of sanctions against the Russian financial sector, cutting off many major banks from the global...more
On December 5, 2022, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $60 per barrel price cap on maritime transfers of Russian-origin crude oil. The final cap level is being implemented...more
On October 24, 2022, the U.S. Department of Treasury Office of Foreign Assets Control (OFAC) and Department of State (State) announced new sanctions designations for Nicaragua, targeting a key state mining company and...more
On October 7, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule (the “Rule”) imposing sweeping new export controls targeting certain advanced computing integrated...more
In the final few days of September, the U.S. and global allies issued a number of sanctions and export controls against actors who have supported Russia’s referendums in Ukraine and related attempts to annex four Ukrainian...more
On August 15, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule introducing new controls on four “emerging and foundational technologies” that were identified during the...more
On May 8, 2022, the White House announced a number of new measures in response to Russia’s ongoing war in Ukraine. The new measures include prohibitions on new categories of services to Russia by U.S. persons; export controls...more
In the last month, the United States and global allies have issued unprecedented sanctions against Russia in response to the war in Ukraine. These sanctions apply ever-expanding pressure on the Russian economy and touch...more
On February 24, 2022, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued a final rule effective immediately imposing sweeping export control restrictions against Russia in response to Russia’s...more
3/3/2022
/ Belarus ,
Belarus Sanctions ,
Bureau of Industry and Security (BIS) ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
General Licenses ,
Licensing Rules ,
Military End Use ,
Russia ,
U.S. Commerce Department ,
Ukraine
On February 24, 2022, the U.S. Government issued a number of sanctions measures in response to Russia’s attack on Ukraine. These measures include sweeping financial sanctions and stringent export controls, which will have...more
2/25/2022
/ Biden Administration ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Embargo ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
U.S. Treasury ,
Ukraine
On October 21, 2021, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) announced an interim final rule (Interim Rule), which will amend the Export Administration Regulations (EAR) to add controls for the...more
U.S., UK and EU authorities continue to expand sanctions targeting the Tatmadaw, Myanmar’s armed forces, following the February 17, 2021, military coup in Myanmar (also known as Burma). Over the past month, the United States...more
U.S. officials have continued to use a range of policy tools to apply pressure on the military leadership of Myanmar (also known as Burma) in response to the military coup in the country and escalating violence against...more
In response to the recent military coup in Myanmar (also known as Burma) against the democratically-elected government, on February 11, 2021 the Biden Administration issued an Executive Order on Blocking Property with Respect...more
On December 14, 2020, the U.S. Department of State initiated a series of sanctions pursuant to Section 231 of the Countering America’s Adversaries Through Sanctions Act (CAATSA) that target the Turkish Presidency of Defense...more
Over the course of the Obama and Trump administrations, U.S. officials have found new ways to incorporate human rights concerns into sanctions and export control policies. Recent announcements by the Commerce and State...more
On September 18, 2020, the U.S. Commerce Department published two rules defining the scope of prohibited transactions related to the mobile applications, WeChat and TikTok. The scope of prohibited transactions clarified the...more
On August 11, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a new guidance document, the Sudan Program and Darfur Sanctions Guidance (“Sudan Guidance”), which clarifies the current...more