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U.S. State Department reinstates Cuba Restricted List

The U.S. Department of State has formally republished the Cuba Restricted List, restoring prohibitions on direct financial transactions with numerous Cuban military, intelligence, and security-linked entities. This move...more

OFAC takes the position that certain kinds of SDN participation in public conferences is not a prohibited service under U.S....

The U.S. Department of Treasury’s Office of Foreign Assets Control issued a formal guidance letter stating that certain kinds of Specially Designated Nationals could speak at a public conference to share their individual...more

U.S. Department of Commerce expands controls on advanced semiconductors and establishes new controls on closed AI model weights

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

The United States and the United Kingdom impose new sanctions against the Russian energy sector

New U.S. and UK sanctions target Russia’s energy sector and supporting infrastructure. On January 10, 2025, the United States and the United Kingdom imposed additional sanctions against Russia, with a focus on its energy...more

BIS seeks public comment on potential rule restricting the import and use of unmanned aircraft systems involving China, Russia and...

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

New DOJ rule limits cross-border data transfers to protect national security

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

DOJ proposes regulations limiting certain data transfers to protect national security

The U.S. remains on course to restrict a broad range of cross border data transfers to China, Russia, and other designated countries. On October 21, 2024, the Department of Justice (DOJ) issued a Notice of Proposed Rulemaking...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 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

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

BIS issues frequently asked questions to clarify the military end use/user rule

On 29 June 2020, the final rule expanding the military end user/user controls (MEU) issued by the Bureau of Industry and Security (BIS) went into effect. On 26 June 2020, BIS issued an FAQs guidance document that provides...more

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