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U.S. proposes revisions to “defense service” definition and related export controls

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

Proposed BIS rules target end users and uses, and U.S. person activity in specified countries

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

BIS issues guidance on addressing diversion risk

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

BIS Issues License Exception MED for Russia, Belarus, Crimea, and covered regions of Ukraine

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

BIS further enhances voluntary self disclosure process for minor or technical violations

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

BIS Issues Three New Rules To Ease Certain Export Licensing Requirements

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

BIS continues to expand export controls on Russia and Belarus and adds 71 entities to the Entity List

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

BIS issues clarifications to the foreign-direct product rules

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

Export controls and immigration: balancing export control compliance with anti-discrimination laws

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

U.S. imposes new sanctions and export controls on Burma

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

BIS issues new rule restricting transactions involving military-intelligence end uses and end users

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

BIS issues new Military End-User List and removes Hong Kong as a Separate Destination Under the EAR

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

Our International Trade team comments on additional restrictions on trade with Cuba [Video]

The Trump Administration announced a more restrictive policy towards Cuba in a presidential memo issued in June 2017. Since then, the Administration has implemented initiatives that have narrowed or revoked authorized trading...more

BIS issues final rule restricting additional exports and reexports to Cuba

On 21 October 2019 the Bureau of Industry and Security (BIS) issued a final rule amending Cuba-related provisions in the Export Administration Regulations (EAR). The new rule further restricts exports and reexports of...more

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