On February 24, 2022, the U.S. imposed sweeping sanctions and export controls actions in response to the Russian Federation’s (“Russia”) “war of choice” against Ukraine. ...more
3/8/2022
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
European Central Bank ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
General Licenses ,
Joe Biden ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
SWIFT ,
U.S. Commerce Department ,
U.S. Treasury ,
Ukraine
Key point: On February 24, 2022, the United States imposed a combination of extensive and complex trade sanctions and export controls against the Russian Federation (Russia) in response to its invasion of Ukraine. These...more
2/28/2022
/ Bureau of Industry and Security (BIS) ,
CAPTA List ,
Commerce Control List ,
ECCNs ,
Economic Sanctions ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
Ukraine
On February 22, 2022, one day after the Russian Federation formally recognized the Donetsk People’s Republic (“DNR”) and Luhansk People’s Republic (“LNR”) of Ukraine as “independent states” and the Biden Administration...more
2/23/2022
/ Banks ,
CBW Act ,
Economic Sanctions ,
Energy Sector ,
Export Administration Regulations (EAR) ,
Financial Services Industry ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
SSI List ,
U.S. Commerce Department ,
U.S. Treasury ,
Ukraine
On February 21, 2022, U.S. President Joseph R. Biden Jr. issued an Executive Order (the “Ukraine Order”) in response to action taken earlier in the day by Russian Federation President Vladimir Putin to recognize the Donetsk...more
Effective January 13, 2022, the U.S. Census Bureau’s (“Census”) Automated Export System (“AES”) began issuing a response code 66Q notifying Electronic Export Information (“EEI”) filers whenever they enter an export control...more
Russia has amassed more than 100,000 troops at the Ukrainian border, leading the White House to issue a warning on January 25 that the U.S. is “prepared to implement sanctions with massive consequences that were not...more
2/2/2022
/ Bureau of Industry and Security (BIS) ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Joe Biden ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
SDN List ,
SWIFT ,
Ukraine
As tensions run high between Washington and Moscow over a possibly imminent Russian invasion of Ukraine, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated today four (4) current and...more
In an October 21, 2021 interim final rule (“IFR”), the Bureau of Industry and Security (“BIS”) published long-awaited “cybersecurity items” controls in Categories 4 (Computers) and 5, Pt. 1 (Telecommunications) of the...more
1/21/2022
/ Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Cybersecurity ,
ECCNs ,
Export Administration Regulations (EAR) ,
Interim Final Rules (IFR) ,
ITAR ,
National Security ,
Popular ,
Software ,
Surveillance
Husch Blackwell’s third-annual international trade law year-in-review report provides a detailed look at how 2021 played out and takes a peek at how 2022 might develop. As companies begin to strategize on what a second year...more
1/4/2022
/ Anti-Dumping Duty ,
China ,
Countervailing Duties ,
Court of International Trade ,
Customs and Border Protection ,
Digital Currency ,
Export Controls ,
False Claims Act (FCA) ,
Free Trade Agreements ,
Imports ,
International Trade ,
NAFTA ,
Office of Foreign Assets Control (OFAC) ,
Patent Trial and Appeal Board ,
Section 301 ,
Supply Chain ,
Tariffs ,
Trade Policy ,
Trade Promotion Authority ,
United States-Mexico-Canada Agreement (USMCA) ,
US-China Economic and Security Review Commission (USCC)
As previously reported, in February 2021, President Biden issued Executive Order 14017 (“EO 14017”), which instructed various government agencies to review the current supply chain risks for critical sectors and subsectors of...more
On October 5, 2021, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule in the Federal Register that places new controls on software and technology that can potentially be used for...more
The Department of Commerce’s (“Commerce”) Bureau of Industry & Security (“BIS”) recently issued requests for comment on risks to the information communications and technology (“ICT”) and semiconductor supply chains...more
On August 20, 2021, U.S. Customs and Border Protection (“CBP”) issued Cargo Systems Messaging Service (“CSMS”) message # 49132200 addressing documentation requirements for import shipments valued over $2,500 to qualify for...more
The Petitioners representing the U.S. domestic industry filed new petitions with the U.S. Department of Commerce (“Commerce”) against imports from three countries, Thailand, Vietnam, and Malaysia, alleging that certain...more
During the past month, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) has issued three separate rounds of Specially Designated Nationals & Blocked Persons List (“SDN List”) designations in order...more
On August 9, 2021, President Biden issued Executive Order 14038 (the “EO”) which expanded the scope of the national emergency previously declared in EO 13405 of June 16, 2006. The EO imposes additional sanctions in response...more
Effective July 2, 2021, as part of the U.S. Government’s ongoing response to the military coup in Burma (Myanmar), the Department of Commerce’s Bureau of Industry and Security (“BIS”) added four entities to the Entity List...more
Earlier this month, the US Government updated its ongoing response to what the Department of Commerce (“Commerce”) described as “Beijing’s campaign of repression, mass detention, and high-technology surveillance against...more
7/23/2021
/ Anti-Money Laundering ,
Bureau of Industry and Security (BIS) ,
China ,
Department of Homeland Security (DHS) ,
Export Administration Regulations (EAR) ,
Military End Use ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
SDN List ,
Surveillance ,
U.S. Commerce Department ,
USTR
The Biden Administration has taken new actions related to forced labor in the Xinjiang region that may affect the supply for material critical for solar panels: U.S. Customs and Border Protection (CBP) issued a Withhold...more
On January 23, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and the U.S. Department of State issued two final rules, available here and here. The final rules outlined the removal of...more
6/9/2021
/ 3D Printing ,
Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Export Administration Regulations (EAR) ,
Exports ,
Federal Register ,
Firearms ,
ITAR ,
Software ,
Technology Sector ,
U.S. Commerce Department ,
US Department of State
Recently, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) sanctioned various individuals and entities connected to Russia’s technology sector and also expanded sanctions against dealings in Russian...more
4/21/2021
/ Biden Administration ,
Cyber Attacks ,
Cyber Crimes ,
Defense Sector ,
Election Interference ,
Executive Orders ,
Export Controls ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanctions ,
SDN List ,
Sovereign Debt ,
State-Owned Enterprises ,
Technology Sector ,
U.S. Treasury
Secretary of Commerce Gina M. Raimondo recently announced that the Department of Commerce (“Commerce”) had served subpoenas on multiple Chinese companies that provide information and communications technology and services...more
3/23/2021
/ Biden Administration ,
Critical Infrastructure Sectors ,
Digital Currency ,
Executive Orders ,
Foreign Adversaries ,
Goods or Services ,
Information and Communication Technology (ICT) ,
National Security ,
Secretary of Commerce ,
Subpoenas ,
Trump Administration ,
U.S. Commerce Department
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued final rules amending the Export Administration Regulations (“EAR”) by implementing new export controls on Burma (Myanmar), and adding four...more
President Biden issued an “Executive Order on America’s Supply Chains” (the “EO”) on February 24, 2021, ordering 100-day and 1-year reviews of certain critical supply chains. The initial 100-day review aims to assess risks...more
The merging of Hong Kong with China with respect to Hong Kong’s treatment under the Export Administration Regulations (“EAR”) is now reflected in the Department of Commerce’s Bureau of Industry and Security’s Hong Kong...more