The U.S. Department of Treasury’s Office of Foreign Assets Control issued a formal guidance letter stating that certain kinds of Specially Designated Nationals could speak at a public conference to share their individual...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
New U.S. and UK sanctions target Russia’s energy sector and supporting infrastructure. On January 10, 2025, the United States and the United Kingdom imposed additional sanctions against Russia, with a focus on its energy...more
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
Earlier this week, efforts to reduce U.S. reliance on biotechnology companies in China stalled when the BIOSECURE Act (“BIOSECURE” or the “Act”) was left out of this week’s continuing resolution (CR). As a result, BIOSECURE...more
On October 30, 2024, the US government imposed additional trade controls to target procurement networks supporting Russia’s military and defense-industrial system. These additional trade controls include sanctioning 400...more
On October 17, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security and the State Department’s Directorate of Defense Trade Controls issued rules to modernize space-related export controls that aim to...more
On July 29, 2024, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) issued a proposed rule to revise the definition of “defense service” and the scope of related controls under existing International...more
On 29 July 2024, the U.S. Department of Commerce’s Bureau of Industry and Security issued two proposed rules that would impose broad new license requirements on items subject to the Export Administration Regulations. The...more
The U.S. Department of Commerce’s Bureau of Industry and Security released an interim final rule (IFR) on July 18th amending the Export Administration Regulations (EAR). This amendment revises the scope of “standards-related...more
The US Department of the Treasury’s Office of Foreign Assets Control has released guidance following on Congress’ extension of the statute of limitations for violations of certain sanctions and related recordkeeping...more
On July 10, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its Guidance to Industry on BIS Actions Identifying Transaction Parties of Diversion Risk (the Guidance) designed to help...more
On 12 June 2024, the US Departments of Treasury, State, and Commerce imposed new restrictions targeting Russia, including: (i) restricting the provision of certain information technology and software services to Russia...more
The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an interim final rule set to take effect August 8, 2024, which amends the Reporting, Procedures, and Penalties Regulations (the “Regulations”)...more
On May 15, 2024, the U.S. Commerce Department’s Bureau of Industry and Security issued an antiboycott compliance advisory regarding the Turkish government’s announcement that it will suspend all imports and exports to and...more
In mid-April, the U.S. Departments of Commerce and State took a series of related actions to support implementation of the Australia, UK, and U.S. Trilateral Security Partnership. On April 19, 2024, BIS issued an Interim...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
On April 10, 2024, the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) published guidance for universities and research centers to comply with International Traffic in Arms Regulations (“ITAR”). DDTC...more
On March 7, 2024, the U.S. Department of Justice’s National Security Division (NSD) issued an updated Enforcement Policy for Business Organizations. The updated policy encourages companies to voluntarily disclose to NSD...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
The BIOSECURE Act (the “Act”), introduced by members of the House Select Committee on the Strategic Competition between the United States and the Chinese Communist Party (“House Select Committee on the CCP”) on January 25,...more
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has further updated its voluntary self-disclosure (VSD) process by establishing streamlined procedures for minor or technical violations of the Export...more
On December 22, 2023, President Biden issued a new Russia-related Executive Order (“EO”) targeting foreign financial institutions (“FFIs”) that support Russia’s military-industrial base. The new EO allows the U.S. government...more
The International Traffic in Arms Regulations, administered by the U.S. Department of State’s Directorate of Defense Trade Controls, and the Export Administration Regulations, administered by the U.S. Department of Commerce’s...more