Key Points -
The Export Control Reform Act of 2018 has been amended to give BIS the authority to regulate services and other activities of U.S. persons, wherever located, when in support of foreign “military, security, or...more
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
Key Points -
On March 7, 2022, new U.S. export controls applicable to “cybersecurity items” took effect based on an interim final rule published by BIS on October 21, 2021 (the “Cyber Rule”). The controls under the Cyber...more
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
Key Points -
The U.S. Department of Commerce has reorganized and clarified the regulations describing when foreign-produced items outside the United States are and are not subject to the licensing and other obligations of...more
- The U.S. Department of Commerce has published a highly complex and novel interim final rule extending the controls of the Export Administration Regulations (EAR) over foreign-made items in Huawei’s contract manufacturing...more
5/21/2020
/ Bureau of Industry and Security (BIS) ,
Comment Period ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Direct Product Rule ,
Foreign Policy ,
General Licenses ,
Huawei ,
Interim Final Rules (IFR) ,
Manufacturers ,
National Security ,
Prohibited Transactions ,
Public Comment ,
Supply Chain ,
Technology Sector ,
Telecommunications ,
U.S. Commerce Department
- 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
4/30/2020
/ Bureau of Industry and Security (BIS) ,
Exceptions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Final Rules ,
General Licenses ,
Licensing Rules ,
Military End Use ,
National Security ,
Proposed Rules ,
U.S. Commerce Department
- BIS extended until May 15, 2020, the Temporary General License authorizing certain exports, reexports, and transfers to Huawei and other listed affiliates of specific types of items that are relevant to third parties.
-...more
3/13/2020
/ Bureau of Industry and Security (BIS) ,
Comment Period ,
Confidential Information ,
Entity List ,
Export Controls ,
Exports ,
General Licenses ,
Huawei ,
National Security ,
Public Comment ,
Technology Sector ,
Time Extensions ,
U.S. Commerce Department
IN THIS ISSUE
• Anticorruption Developments
• Export Control Sanctions and Customs Enforcement
• Export Control and Sanctions Developments
• Global Investigations Resources
• Writing and Speaking...more
2/26/2020
/ Anti-Corruption ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Civil Monetary Penalty ,
Criminal Conspiracy ,
Criminal Convictions ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Due Process ,
Economic Sanctions ,
Enforcement Actions ,
Executive Orders ,
Export Control Reform Act (ECRA) ,
Export Controls ,
Exports ,
Fifth Amendment ,
Forced Labor ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
Guilty Pleas ,
Imports ,
Indictments ,
ITAR ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Red Notices ,
Sanction Violations ,
Sanctions ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Smuggling ,
Trump Administration ,
U.S. Treasury ,
Whistleblowers
• The Commerce Department’s Bureau of Industry and Security (BIS) has added 46 additional Huawei affiliates to the Entity List. The export, reexport, and transfer to these entities of commodities, software, and technology...more
8/21/2019
/ Bureau of Industry and Security (BIS) ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
General Licenses ,
Huawei ,
Prohibited Transactions ,
Software ,
Technology Sector ,
Telecommunications ,
U.S. Commerce Department
• The Department of Commerce has announced that it plans to eliminate License Exception CIV (civil end-users) from the Export Administration Regulations (EAR).
• Businesses who use or have considered using License...more
• Since the addition of Huawei and many of its affiliates to the Entity List, there has been significant media coverage over which types of transactions involving the listed entities are, and are not, prohibited without a...more
5/29/2019
/ Bureau of Industry and Security (BIS) ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
General Licenses ,
Huawei ,
National Security ,
Prohibited Transactions ,
Software ,
Technology Sector ,
Telecommunications ,
U.S. Commerce Department
• On May 20, 2019, the U.S. Department of Commerce published a 90-day Temporary General License (TGL) authorizing limited categories of exports, reexports, or transfers that are otherwise prohibited pursuant to the addition...more
5/22/2019
/ Bureau of Industry and Security (BIS) ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
General Licenses ,
Huawei ,
Manufacturers ,
National Security ,
Prohibited Transactions ,
Supply Chain ,
Technology Sector ,
Telecommunications ,
U.S. Commerce Department
• On May 16, 2019, the U.S. Department of Commerce published a final rule adding Huawei and 68 other companies, mostly its non-U.S. affiliates worldwide, to the Entity List... The rule will be officially published in the...more
5/20/2019
/ Bureau of Industry and Security (BIS) ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Final Rules ,
Foreign Policy ,
General Licenses ,
Huawei ,
National Security ,
Technology Sector ,
U.S. Commerce Department
ANTICORRUPTION DEVELOPMENTS -
DOJ Files Superseding Indictment in Haitian Port Corruption Plot -
On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more
11/20/2018
/ Adidas ,
Anti-Corruption ,
Banking Sector ,
Bribery ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
College Athletes ,
Commerce Control List ,
Corporate Monitoring ,
Criminal Conspiracy ,
Criminal Convictions ,
Criminal Prosecution ,
Customs and Border Protection ,
Cybersecurity ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Federal Pilot Programs ,
Financial Institutions ,
FinCEN ,
FIRRMA ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Policy ,
Former Employee ,
General Licenses ,
Indictments ,
Interim Final Rules (IFR) ,
Internal Controls ,
ITAR ,
JPMorgan Chase ,
Jurisdiction ,
Medical Devices ,
Money Laundering ,
National Security ,
NCAA ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Settlement ,
SFO ,
Shipping ,
Technology Sector ,
U.S. Commerce Department ,
U.S. Treasury ,
United States-Mexico-Canada Agreement (USMCA) ,
US State Departments ,
USML ,
Whistleblower Awards ,
Whistleblowers ,
Wire Fraud ,
World Bank
ANTICORRUPTION DEVELOPMENTS -
DOJ Files Superseding Indictment in Haitian Port Corruption Plot -
On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more
11/20/2018
/ Adidas ,
Anti-Corruption ,
Banking Sector ,
Bribery ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
College Athletes ,
Commerce Control List ,
Corporate Monitoring ,
Criminal Conspiracy ,
Criminal Convictions ,
Criminal Prosecution ,
Customs and Border Protection ,
Cybersecurity ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Federal Pilot Programs ,
Financial Institutions ,
FinCEN ,
FIRRMA ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Policy ,
Former Employee ,
General Licenses ,
Indictments ,
Interim Final Rules (IFR) ,
Internal Controls ,
ITAR ,
JPMorgan Chase ,
Jurisdiction ,
Medical Devices ,
Money Laundering ,
National Security ,
NCAA ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Settlement ,
SFO ,
Shipping ,
Technology Sector ,
U.S. Commerce Department ,
U.S. Treasury ,
United States-Mexico-Canada Agreement (USMCA) ,
US State Departments ,
USML ,
Whistleblower Awards ,
Whistleblowers ,
Wire Fraud ,
World Bank
ANTICORRUPTION DEVELOPMENTS -
DOJ Files Superseding Indictment in Haitian Port Corruption Plot -
On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more
11/20/2018
/ Adidas ,
Anti-Corruption ,
Banking Sector ,
Bribery ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
College Athletes ,
Commerce Control List ,
Corporate Monitoring ,
Criminal Conspiracy ,
Criminal Convictions ,
Criminal Prosecution ,
Customs and Border Protection ,
Cybersecurity ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Federal Pilot Programs ,
Financial Institutions ,
FinCEN ,
FIRRMA ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Policy ,
Former Employee ,
General Licenses ,
Indictments ,
Interim Final Rules (IFR) ,
Internal Controls ,
ITAR ,
JPMorgan Chase ,
Jurisdiction ,
Medical Devices ,
Money Laundering ,
National Security ,
NCAA ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Settlement ,
SFO ,
Shipping ,
Technology Sector ,
U.S. Commerce Department ,
U.S. Treasury ,
United States-Mexico-Canada Agreement (USMCA) ,
US State Departments ,
USML ,
Whistleblower Awards ,
Whistleblowers ,
Wire Fraud ,
World Bank
ANTICORRUPTION DEVELOPMENTS -
DOJ Files Superseding Indictment in Haitian Port Corruption Plot -
On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more
11/5/2018
/ Adidas ,
Anti-Corruption ,
Banking Sector ,
Bribery ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
College Athletes ,
Commerce Control List ,
Corporate Monitoring ,
Criminal Conspiracy ,
Criminal Convictions ,
Criminal Prosecution ,
Customs and Border Protection ,
Cybersecurity ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Federal Pilot Programs ,
Financial Institutions ,
FinCEN ,
FIRRMA ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Policy ,
Former Employee ,
General Licenses ,
Indictments ,
Interim Final Rules (IFR) ,
Internal Controls ,
ITAR ,
JPMorgan Chase ,
Jurisdiction ,
Medical Devices ,
Money Laundering ,
National Security ,
NCAA ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Settlement ,
SFO ,
Shipping ,
Technology Sector ,
U.S. Commerce Department ,
U.S. Treasury ,
United States-Mexico-Canada Agreement (USMCA) ,
US State Departments ,
USML ,
Whistleblower Awards ,
Whistleblowers ,
Wire Fraud ,
World Bank
ANTICORRUPTION DEVELOPMENTS -
Petrobras Settles with U.S. Authorities Over Alleged FCPA Violations -
On September 27, 2018, the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC)...more
10/2/2018
/ Anti-Corruption ,
Arms Export Control Act ,
Books & Records ,
Bureau of Industry and Security (BIS) ,
CAATSA ,
CEOs ,
Civil Monetary Penalty ,
Comment Period ,
Consent Order ,
Corporate Fines ,
Country of Origin ,
Criminal Conspiracy ,
Criminal Prosecution ,
Customs ,
Defense Contracts ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Emerging Growth Companies ,
Energy Sector ,
Enforcement Actions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Control Reform (ECR) ,
Export Controls ,
Exports ,
Federal Trade Commission (FTC) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Interference in US Elections ,
General Licenses ,
Guilty Pleas ,
Indictments ,
Investigations ,
ITSR ,
List of Specified Persons (LSP) ,
Manufacturers ,
Mining ,
Money Laundering ,
National Security ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Pharmaceutical Industry ,
Public Comment ,
Real Estate Brokers ,
Recordkeeping Requirements ,
Remand ,
Reporting Requirements ,
Retailers ,
Securities and Exchange Commission (SEC) ,
Settlement Agreements ,
SFO ,
Testimony ,
Trump Administration ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
Wire Fraud
ANTICORRUPTION DEVELOPMENTS -
$34 Million SEC Settlement for Legg Mason -
On August 27, 2018, the Securities and Exchange Commission (SEC) announced that Legg Mason Inc. will pay more than $34 million to settle an...more
9/6/2018
/ 3-D Technology ,
Anti-Corruption ,
Appeals ,
Berry Amendment ,
Bribery ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Civil Monetary Penalty ,
Corruption ,
Criminal Conspiracy ,
Criminal Penalties ,
Criminal Prosecution ,
Critical Infrastructure Sectors ,
Customs and Border Protection ,
Declination ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Embezzlement ,
Enforcement Actions ,
Entity List ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Filing Requirements ,
FIRRMA ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Investment ,
Foreign Policy ,
Former Employee ,
General Licenses ,
Guilty Pleas ,
Immigration and Customs Enforcement (ICE) ,
Imports ,
Insurance Contracts ,
Internal Investigations ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Jurisdiction ,
Licensing Rules ,
Money Laundering ,
National Security ,
NDAA ,
New Legislation ,
Office of Foreign Assets Control (OFAC) ,
Personal Data ,
Preliminary Injunctions ,
Probationary Period ,
Racketeering ,
Sanction Violations ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Settlement Agreements ,
SFO ,
Suspensions & Debarments ,
The Wassenaar Arrangement ,
Trade Agreements Act ,
Trump Administration ,
Wire Fraud ,
World Bank
ANTICORRUPTION DEVELOPMENTS -
SEC Proposes Amendments to Whistleblower Award Program -
On June 28, 2018, the Securities and Exchange Commission (SEC) proposed amendments to its whistleblower award process for the first...more
7/11/2018
/ Anti-Corruption ,
Bureau of Industry and Security (BIS) ,
CAATSA ,
Civil Monetary Penalty ,
Criminal Prosecution ,
Cybersecurity ,
Department of Justice (DOJ) ,
Director Nominations ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
False Statements ,
Fines ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
General Licenses ,
Hiring & Firing ,
Indictments ,
International Emergency Economic Powers Act (IEEPA) ,
ITSR ,
Joint Comprehensive Plan of Action (JCPOA) ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Proposed Amendments ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Settlement Agreements ,
Telecommunications ,
U.S. Commerce Department ,
UK ,
Whistleblower Awards ,
Wire Fraud ,
ZTE
ANTICORRUPTION DEVELOPMENTS -
SEC Proposes Amendments to Whistleblower Award Program -
On June 28, 2018, the Securities and Exchange Commission (SEC) proposed amendments to its whistleblower award process for the first...more
7/11/2018
/ Anti-Corruption ,
Bureau of Industry and Security (BIS) ,
CAATSA ,
Civil Monetary Penalty ,
Criminal Prosecution ,
Cybersecurity ,
Department of Justice (DOJ) ,
Director Nominations ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
False Statements ,
Fines ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
General Licenses ,
Hiring & Firing ,
Indictments ,
International Emergency Economic Powers Act (IEEPA) ,
ITSR ,
Joint Comprehensive Plan of Action (JCPOA) ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Proposed Amendments ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Settlement Agreements ,
Telecommunications ,
U.S. Commerce Department ,
UK ,
Whistleblower Awards ,
Wire Fraud ,
ZTE
ANTICORRUPTION DEVELOPMENTS -
SEC Proposes Amendments to Whistleblower Award Program -
On June 28, 2018, the Securities and Exchange Commission (SEC) proposed amendments to its whistleblower award process for the first...more
7/11/2018
/ Anti-Corruption ,
Bureau of Industry and Security (BIS) ,
CAATSA ,
Civil Monetary Penalty ,
Criminal Prosecution ,
Cybersecurity ,
Department of Justice (DOJ) ,
Director Nominations ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
False Statements ,
Fines ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
General Licenses ,
Hiring & Firing ,
Indictments ,
International Emergency Economic Powers Act (IEEPA) ,
ITSR ,
Joint Comprehensive Plan of Action (JCPOA) ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Proposed Amendments ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Settlement Agreements ,
Telecommunications ,
U.S. Commerce Department ,
UK ,
Whistleblower Awards ,
Wire Fraud ,
ZTE
ANTICORRUPTION DEVELOPMENTS -
SEC Proposes Amendments to Whistleblower Award Program -
On June 28, 2018, the Securities and Exchange Commission (SEC) proposed amendments to its whistleblower award process for the first...more
7/11/2018
/ Anti-Corruption ,
Bureau of Industry and Security (BIS) ,
CAATSA ,
Civil Monetary Penalty ,
Criminal Prosecution ,
Cybersecurity ,
Department of Justice (DOJ) ,
Director Nominations ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
False Statements ,
Fines ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
General Licenses ,
Hiring & Firing ,
Indictments ,
International Emergency Economic Powers Act (IEEPA) ,
ITSR ,
Joint Comprehensive Plan of Action (JCPOA) ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Proposed Amendments ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Settlement Agreements ,
Telecommunications ,
U.S. Commerce Department ,
UK ,
Whistleblower Awards ,
Wire Fraud ,
ZTE
ANTICORRUPTION DEVELOPMENTS -
SEC Proposes Amendments to Whistleblower Award Program -
On June 28, 2018, the Securities and Exchange Commission (SEC) proposed amendments to its whistleblower award process for the first...more
7/10/2018
/ Anti-Corruption ,
Bureau of Industry and Security (BIS) ,
CAATSA ,
Civil Monetary Penalty ,
Criminal Prosecution ,
Cybersecurity ,
Department of Justice (DOJ) ,
Director Nominations ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
False Statements ,
Fines ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
General Licenses ,
Hiring & Firing ,
Indictments ,
International Emergency Economic Powers Act (IEEPA) ,
ITSR ,
Joint Comprehensive Plan of Action (JCPOA) ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Proposed Amendments ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Settlement Agreements ,
Telecommunications ,
U.S. Commerce Department ,
UK ,
Whistleblower Awards ,
Wire Fraud ,
ZTE