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BIS Issues New Guidance to Combat Russia Diversion Risks and Highlights Recent Enforcement Actions

Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance to exporters intended to further assist BIS in its efforts to crack down on third-party diversion to Russia. ...more

Commerce Department Bans Kaspersky Software in First ICTS Prohibition, Signals Increased Risk of Using Certain Foreign Software...

On June 20, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a Final Determination prohibiting the sale of certain cybersecurity products, anti-virus software, and related services to...more

OFAC and U.S. Department of State Issue New Sanctions and Designates More Than 300 Russian Federation Individuals and Companies...

On Friday, May 19, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced the addition of more than 300 Russian Federation individuals and companies as well as other individuals and...more

BIS Implements Additional Export Controls and Entity List Additions Targeting Russia to Align with Allies and Partners

On May 19, 2023, the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced new export controls and Entity List additions during President Biden’s G7 visit in Japan. In conjunction with the G7 meetings,...more

BIS Levies Record Penalty for Export Control Violations related to Huawei Shipments

Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced the issuance of a $300 million penalty against Seagate Technology LLC and its Singapore affiliate, Seagate Singapore International...more

Recent Actions Illustrate Continued Focus on Export Control Violations

Last week, Deputy Attorney General Lisa Monaco’s statements to the American Bar Association again highlighted the fact that investigating and prosecuting individuals for violating economic sanctions, export controls, and...more

BIS Issues New Export Controls and Entity List Additions Targeting Russia on One-Year Anniversary of Invasion

The Department of Commerce’s Bureau of Industry and Security (“BIS”) announced today new export controls and Entity List additions designed to further restrict Russia’s ability to maintain its continued war against Ukraine....more

Export Control Violations Result in Significant Monetary Penalties and Continuing Compliance Training Obligations

In a recent order, the Department of Commerce’s Bureau of Industry and Security (“BIS”) revoked the export privileges for Obaidullah Sayed, an Illinois resident. Sayed was convicted of conspiring to export computers, computer...more

Biden Administration No Longer Approving Export Licenses to Chinese Tech Giant Huawei

According to recent reports, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) has stopped granting export licenses to Huawei Technologies Co. Ltd. (“Huawei”). The U.S. government has long sought to...more

BIS Adds 35 Chinese Entities to Entity List for Supporting China’s Military Modernization Efforts and Nine Russian Entities for...

On December 16, 2022, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) published a rule adding 35 entities from China and one entity from Japan to the Entity List for supporting China’s military...more

BIS Adds 24 New Entities and Removes One from Entity List and Extends Deadline for Comments to New Semiconductor Rules

On December 8, 2022, the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a notice in the Federal Register adding 24 entities under 26 entries and removing one entity from the Entity List....more

U.S. Departments of Treasury and State Expand Sanctions To Restrict Russia’s Access to Services and Economics and Combat Evasion...

On June 28, 2022, the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a Joint Alert urging financial institutions...more

BIS Adds 71 Entities to Entity List; Issues Russia/Belarus Corrections and Clarifications; and Updates EAR to Allow Immediate...

On June 2, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) updated the Export Administration Regulations (“EAR”) to: (i) add 71 entities to the Entity List “for acquiring or attempting to...more

BIS Considers More Public and Expensive Consequences for Companies Violating the EAR

Matthew Axelrod, the Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), told a conference held by the Society for International Affairs on May 16, 2022,...more

BIS Expands List of Items Subject to EAR Russia Industry Sector Sanctions Effective Immediately

On May 9, 2022, the Bureau of Industry and Security (“BIS”) released for public inspection a Final Rule adding hundreds of new items to a list of restricted items in Supplement No. 4 to Part 746 of the U.S. Export...more

BIS Modifies and Expands List of Russian-Controlled Aircraft Subject to the EAR Known or Suspected to Have Violated the EAR

On March 30, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) modified and expanded a list of aircraft that have flown into Russia in apparent violation of the Export Administration Regulations...more

BIS Signals Aggressive Enforcement Approach to Russia-Related EAR Violations

On March 18, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) publicly identified certain commercial and private aircraft that have entered Russia in likely violation of the Export...more

U.S. Imposes More Russian Sanctions and Export Controls on Consumer Items and Luxury Goods, U.S. Dollar-Denominated Banknote...

On Friday, March 11, 2022, the White House issued Executive Order (“EO”) 14068 announcing more sanctions and export controls against the Russian Federation (“Russia”). Concurrent with that announcement, the U.S....more

U.S. Imposes More Sanctions and Export Controls against Russia and Belarus

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

New U.S. Sanctions and Export Controls Aim to Impose "Devastating Costs" on Russia

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

U.S. Government Signals that Increased Sanctions and Export Controls Will Likely Follow if Russia Invades Ukraine

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

BIS Delays Implementation of New Cybersecurity Items Interim Final Rule

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

BIS Imposes New Export Restrictions on Software for Biological Equipment

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

BIS Requests Comments from Information and Communications Technology (ICT) and Semiconductor Supply Chains on Supply Chain...

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

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