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Significant New U.S. Person and Other Export Controls Proposed Regarding Military, Intelligence, and Security End Users

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has published proposed amendments to the Export Administration Regulations (EAR) that would significantly expand the scope of the export controls over...more

Commerce Imposes Significant New Controls on Advanced Semiconductors

On October 17, 2023, the Commerce Department’s Bureau of Industry and Security (BIS) released three rules amending the Export Administration Regulations (EAR) that significantly build on the October 7, 2022 semiconductor...more

Tri-Seal Compliance Note: Voluntary Self-Disclosure of Potential Violations

On July 26, 2023, the departments of Commerce, Justice and the Treasury issued their second ever to date “Tri-Seal Compliance Note” (the “Note”). It describes expectations for the voluntary disclosure of sanctions, export,...more

Russia, China, Semiconductors and Reimagining National Security: US Export Controls 2022 Year in Review

The volume and impact of changes to United States export control regulations in 2022 were unprecedented, and we expect 2023 will likely bring additional changes. This alert provides a summary of key changes, themes and...more

BIS Imposes New Controls to Limit the Development and Production of Advanced Computing and Semiconductor Capabilities in China

The Commerce Department’s Bureau of Industry and Security (BIS) has amended the Export Administration Regulations (EAR) to impose a series of significant new export controls designed to limit the development and production in...more

Commerce Department Publishes Updated Guidance on Antiboycott Enforcement Policies

Background - U.S. antiboycott laws, which are divided into two separate regimes administered by the U.S. Department of Commerce and the U.S. Department of the Treasury, prohibit U.S. persons from participating in foreign...more

U.S. Government Imposes Expansive, Novel and Plurilateral Export Controls Against Russia and Belarus

Key Points - As part of highly coordinated U.S. government and allied and partner country responses to Russia’s further invasion of Ukraine, and Belarus’ enabling of it, BIS imposed on February 24, 2022, and March 2,...more

Licenses for Exports to Russia Related to Commercial Space Launches Must be Granted by September 1, 2021

As part of the United States’ response to Russia’s use of chemical weapons against Russian opposition figure Aleksey Navalny, the U.S. State Department applied a policy of denial to licenses and other approvals for exports to...more

Treasury Removes UAE from List of Countries Requiring Cooperation with an International Boycott

Key Points - On April 8, the Treasury Department removed the UAE from its list of countries requiring cooperation with an international boycott, thereby removing the UAE from the scope of the Treasury Department’s...more

Biden Administration Issues New Sanctions and Export Controls to Respond to Coup in Burma

Key Points - On February 11, 2021, in the first deployment of sanctions since assuming office, President Biden issued EO 14014, authorizing sanctions against members of the Burmese military and related parties responsible...more

Treasury Proposes CFIUS Mandatory Filing Based on Export Licensing

- On May 21, 2020, Treasury published a Proposed Rule to align the CFIUS mandatory filing framework for transactions involving critical technologies with existing export-licensing requirements. - Under the Proposed Rule,...more

BIS Announces the Elimination of License Exception CIV, Expanded Licensing Requirements on Exports to Chinese, Russian, and...

- On April 28, 2020, the Bureau of Industry and Security of the U.S. Department of Commerce announced changes to the Export Administration Regulations (EAR) through three notices published on the Federal Register. The changes...more

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