General License (GL) 25 authorizes transactions previously prohibited by various regulations. Specifically, Section (a) broadly authorizes activities previously prohibited under the Office of Foreign Asset Control (OFAC)’s...more
Through Aerospace & Defense Insights, we share with you the top legal and political issues affecting the aerospace and defense (A&D) industry. Our A&D sector team monitors the latest developments to help our clients stay in...more
The new interim final rule imposes new global licensing requirements for ECCNs 3A090.a, 4A090.a, and corresponding .z items; controls for closed AI model weights; updated data center validated end-user authorizations;...more
President Trump’s Day 1 presidential memorandum directs a top-to-bottom review of U.S. trade and economic policy and requests that his Administration provide policy recommendations with respect to: the U.S. trade deficit and...more
1/28/2025
/ China ,
Export Controls ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Section 301 ,
Tariffs ,
Trade Relations ,
Trump Administration ,
U.S. Commerce Department ,
U.S. Treasury ,
USTR
On January 14, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) published the Final Rule addressing national security risks associated with connected vehicle technologies. The final rule, which...more
On January 3, 2025 the U.S. Department of Commerce’s Bureau of Industry and Security released an advanced notice of proposed rule-making seeking public input on the definition of “unmanned aircraft systems” and their...more
1/23/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Cybersecurity ,
Executive Orders ,
Export Controls ,
National Security ,
Risk Management ,
Russia ,
Supply Chain ,
U.S. Commerce Department ,
Unmanned Aircraft Systems
On January 6, 2025, the U.S. Department of Defense updated its 1260H List, bringing the total to 134 entities across sectors like AI, aerospace, and biotechnology. Designation on the list signals risks such as restrictions on...more
1/20/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Defense Sector ,
Department of Defense (DOD) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Military End Use ,
National Security ,
NDAA ,
Risk Management
The Department of Justice (DOJ) has issued a final rule limiting data transfers to China, Russia, and other designated “countries of concern.” The rule establishes a new national security program that bans specific types of...more
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) recently issued new guidance for financial institutions (FIs) to comply with the Export Administration Regulations (EAR). Released on 9 October 2024, the...more
On April 29, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule to add a new license exception for medical devices (License Exception MED) to authorize the export, reexport, and...more
The Department of Commerce’s Bureau of Industry and Security published an interim final rule to expand, correct, and clarify the two interim final rules published on October 25, 2023 with respect to semiconductor...more
On March 14, 2024, the State Department and the Commerce Department’s Bureau of Industry and Security (BIS) published corresponding Final Rules that add Nicaragua to the International Trafficking in Arms Regulations (ITAR) §...more
Following the death of political activist Aleksey Navalny and to mark the second anniversary of Russia’s invasion of Ukraine, the United States, EU and UK adopted a series of amendments to their respective economic sanctions...more
On December 8, 2023, the Bureau of Industry and Security (BIS) issued three separate rules to amend the Export Administration Regulations (EAR) to liberalize several categories of export licensing requirements and make...more
On December 12, the Select Committee on the Chinese Communist Party of the U.S. House of Representatives issued a comprehensive economic strategy containing over 160 policy recommendations intended to “to fundamentally reset...more
The Department of Commerce’s Bureau of Industry and Security issued two interim final rules to expand on the 7 October 2022 restrictions aimed at denying access to certain advanced semiconductors, semiconductor manufacturing...more
The Department of Commerce’s Bureau of Industry and Security and the Nuclear Regulatory Commission have issued new licensing requirements on exports of certain civil nuclear hardware, software, and technology to the People’s...more
The U.S. Departments of Commerce, Justice and Treasury have issued a “Tri-Seal” Compliance Note regarding national security laws and regulations and the voluntary self-disclosure of potential violations, highlighting...more
8/2/2023
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Export Administration Regulations (EAR) ,
Export Controls ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
U.S. Treasury ,
Voluntary Disclosure
On May 19, 2023, the US Department of Treasury, State, and Commerce imposed the most significant tranche of sanctions and export control measures in several months. The measures included (i) new designations on the Specially...more
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) clarified its policy regarding voluntary self-disclosures and enforcement actions on April 18, 2023. Historically, a failure to voluntarily...more
In 2021, the Export Controls and Human Rights Initiative (“ECHRI”) was launched at the first Summit for Democracy as part of the Presidential Initiative for Democratic Renewal. This year, during the Summit for Democracy 2023...more
On February 16, 2023, the Department of Justice (DOJ) and the Department of Commerce (Commerce) announced the creation of a joint Disruptive Technology Strike Force (Strike Force). The Strike Force will be co-led by the...more
3/7/2023
/ Bureau of Industry and Security (BIS) ,
CFIUS ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Technology Sector ,
U.S. Commerce Department
Through Aerospace & Defense Insights, we share with you the top legal and political issues affecting the aerospace and defense (A&D) industry. Our A&D industry team monitors the latest developments to help our clients stay in...more
The United States Department of Commerce’s Bureau of Industry and Security has issued regulations to amend the Export Administration Regulations to implement changes to controls of certain viruses, marine toxins, plant...more
The United States government is increasingly scrutinizing U.S. industry’s reliance on China for biotechnology research and development and manufacturing, and is taking steps to expand export control requirements on China that...more
10/24/2022
/ Biotechnology ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Executive Orders ,
Export Control Reform Act (ECRA) ,
Export Controls ,
FIRRMA ,
National Security ,
Popular ,
Research and Development ,
Technology Sector