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
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
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
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 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
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
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
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 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 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 24 February 2023, the U.S. intensified its sanctions on Russia and released new trade control measures targeting key sectors, evasion efforts, and military supplies. Taken together, the additional sanctions, export...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 industry team monitors the latest developments to help our clients stay in...more
On 2 June 2022, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) issued two final rules, effective on the same day, that revised the Export Administration Regulations (“EAR”) pertaining to the U.S.’s...more
The Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) No. 22 on May 12, 2022, authorizing transactions that are ordinarily incident and necessary to activities that occur in specified, non-regime held...more
On February 24, 2022, the US Government imposed severe economic sanctions and export controls on Russia. The restrictions consist of two parts: 1) significant financial sanctions on a range of Russian financial institutions...more
The Bureau of Industry and Security (“BIS”) clarified, reorganized, and made minor corrections to the provisions of the foreign-direct product (“FDP”) rules on February 3, 2022. These revisions aim to consolidate and clarify...more
On January 26, 2022, the U.S. Department of the Treasury issued an advisory for businesses and individuals doing business in Burma. Specifically, the business advisory cautions business and individuals to be aware of exposure...more
2/11/2022
/ Anti-Corruption ,
Anti-Money Laundering ,
Burma ,
Construction Project ,
Export Controls ,
Human Rights ,
ITAR ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
State-Owned Enterprises ,
U.S. Treasury
The release of data to a foreign person, even within U.S. borders, is deemed by U.S. export control laws to be an export to the recipient's country of permanent residency or citizenship. The delivery of U.S. export-controlled...more
On 11 February 2021, President Biden issued Executive Order 14014 "Blocking Property with Respect to Burma" (EO), which authorizes the imposition of sanctions on specific persons or entities in Burma, including Burmese...more
2/23/2021
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
Foreign Policy ,
Insurrection ,
Myanmar ,
Office of Foreign Assets Control (OFAC) ,
SDN List
On 15 January 2021, the Bureau of Industry and Security (BIS) published an interim final rule imposing new restrictions requiring licenses for transactions involving exports, reexports, or transfers, as well as certain...more
On 23 December 2020, BIS created a new Military End User List, naming more than 100 Chinese and Russian companies subject to the enhanced licensing requirements of section 744.21 of the EAR....more
12/31/2020
/ Bureau of Industry and Security (BIS) ,
China ,
Department of Defense (DOD) ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Hong Kong ,
Licensing Rules ,
Military End Use ,
National Security ,
Russia
The State Department announced the imposition of sanctions on the Republic of Turkey’s Presidency of Defense Industries (“SSB”), and four related Turkish individuals under the Countering America’s Adversaries Through...more