On March 29, 2024, BIS issued an interim final rule (IFR) updating and correcting its advanced computing and semiconductor regulations published in October 2023 (which we discuss here in Episode III). This marks the third...more
On Wednesday, March 6, 2024, the Department of Commerce, Department of the Treasury and Department of Justice issued another Tri-seal Compliance Note, focusing this time on the obligations of foreign based persons complying...more
3/8/2024
/ China ,
De Minimis Claims ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Entities ,
Russia ,
Sanctions ,
U.S. Commerce Department ,
U.S. Treasury
On Tuesday, October 17, 2023, the U.S. Bureau of Industry and Security (BIS) released a package of three rules (the 2023 Rules) targeting the Chinese semiconductor industry. The rules update the substantial semiconductor...more
10/23/2023
/ China ,
Commerce Control List ,
ECCNs ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Semiconductors ,
Software ,
Technology ,
Trade Restrictions
In response to Russia’s ongoing aggression in Ukraine, both the United States and the European Union have imposed additional sanctions and further restricted exports to Russia and Iran. These new controls span many...more
2/28/2023
/ Economic Sanctions ,
Entity List ,
EU ,
Export Controls ,
Exports ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions ,
UK ,
Ukraine
On Sunday, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced novel and sweeping sanctions on specific categories of services in order to cripple Russia’s wartime capabilities and sanctioned key...more
5/12/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Final Rules ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia
Last week, the United States government imposed additional restrictions on the imports from, and exports to, Russia. The import changes stem from the Suspending Normal Trade Relations with Russia and Belarus Act, signed into...more
4/14/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Imports ,
Russia ,
Supply Chain ,
Trade Relations ,
Trade Restrictions ,
Ukraine
Updated as of February 25, 2022 -
Key Takeaways of OFAC (Treasury) and BIS (Commerce) Actions -
Major Russian Banks Blocked from the U.S. Financial System. Six major Russian banks — VEB, Promsvyazbank (PSB), VTB Bank,...more
Updated as of February 25, 2022 -
Key Takeaways of EU and UK Recent Actions Against Russia and Ukraine Breakaway Regions -
The EU adopted the first tranche of sanctions restrictions targeting financial institutions, other...more
How do you tackle the complicated and often seemingly insurmountable problem of human rights abuses around the world? The U.S. Government typically uses a variety of tools: diplomatic efforts, international aid, sanctions,...more
If your company is like many, your board of directors may be demanding that you put more effort into environmental, social, and governance issues, which have become known by the now-ubiquitous acronym “ESG.” Those demands...more
10/11/2021
/ Board of Directors ,
Customs ,
Customs and Border Protection ,
Environmental Social & Governance (ESG) ,
Ethical Standards ,
Exports ,
Forced Labor ,
Imports ,
International Trade ,
Sanctions ,
Supply Chain ,
Trade Policy
Companies are putting forth more effort, thought, commitment, and resources into environmental, social, and corporate governance (ESG) considerations across their business lines. The focus of ESG has primarily centered around...more
• Emerging technology sectors are being reviewed now for new export controls that could take effect in 2019 (list below).
• You may submit comments on the criteria the U.S. government will use to determine what technologies...more
12/11/2018
/ Comment Period ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Emerging Technology Companies ,
Export Controls ,
Exports ,
Foreign Nationals ,
National Security ,
Proposed Rules ,
Public Comment ,
Technology Sector
With fewer than 100 days left in office, President Obama is not slowing down on his efforts to normalize relations between the United States and Cuba. Today, several changes to the Cuban Assets Control Regulations (CACR) and...more
10/18/2016
/ Aviation Industry ,
Barack Obama ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Energy Sector ,
Export Administration Regulations (EAR) ,
Exports ,
Imports ,
Medical Research ,
Office of Foreign Assets Control (OFAC) ,
Travel
After a twelve-year standoff that saw the United States and Europe ratchet up sanctions pressure on Iran, a diplomatic breakthrough has been reached. But robust trade between Iran and the West will not arise immediately,...more
7/19/2015
/ EU ,
Exports ,
IFCA ,
Iran ,
Iran Sanctions ,
Iran Threat Reduction and Syria Human Rights Act ,
Joint Comprehensive Plan of Action (JCPOA) ,
Manufacturers ,
NDAA ,
Non-US Entities ,
Nuclear Power ,
Nuclear Weapons
New regulations on Cuba enter into force today, only 29 days after President Obama promised them. The liberalized provisions focus on support for private sector actors in Cuba. As we described here, the President announced on...more
We frequently discuss enforcement actions in this blog, because understanding enforcement is a key aspect of trade compliance. From a fifty-thousand foot view, each enforcement case serves as a cautionary tale about the...more
7/16/2014
/ Aerospace ,
Bureau of Industry and Security (BIS) ,
Burma ,
Enforcement ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Exports ,
Fokker ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Sanctions ,
Settlement ,
Sudan ,
Trade Policy
In Episode I and Episode II of this series, we discussed some key points of U.S. Export Control Reform and took you through a step-by-step reclassification analysis of parts and components transitioning from the USML to the...more