The U.S. Department of Commerce's Bureau of Industry and Security ("BIS") recently released two rules to update export controls on advanced semiconductors, semiconductor development and production, and items that support...more
In a coordinated announcement, federal agencies stress the benefits of voluntarily disclosing potential trade violations while emphasizing increased enforcement....more
8/22/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Economic Sanctions ,
Export Controls ,
FinCEN ,
Foreign Agents Registration Act (FARA) ,
National Security ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
U.S. Commerce Department ,
U.S. Treasury ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes
In Short -
The Situation: On October 7, 2022, the U.S. government announced new regulations aimed at restricting China's ability to manufacture advanced semiconductors, obtain advanced computing chips, and develop and...more
As a response to the Russian invasion of Ukraine starting in late February 2022, Australia, the European Union, Japan, the United Kingdom, the United States, and many other countries have progressively imposed increasingly...more
The U.S. Department of the Treasury has removed the United Arab Emirates from its latest "List of Countries Requiring Cooperation With an International Boycott," easing certain tax reporting requirements.
On April 8, 2021,...more
The U.S. Department of Commerce’s Bureau of Industry and Security ("BIS") recently revised the Export Administration Regulations ("EAR") to, among other things, modify reporting and self-classification requirements for...more
The Bureau of Industry and Security ("BIS") has established a "Military End-User" List ("MEU List"), adding an initial tranche of Chinese and Russian entities to the list.
On December 23, 2020, BIS issued a final rule...more
The Development: China's Ministry of Commerce ("MOFCOM") released Rules on Counteracting Unjustified Extra-Territorial Application of Foreign Laws and Other Measures ("Rules") on January 9, 2021. Effective immediately, the...more
On November 12, 2020, President Trump issued an Executive Order titled "Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies," which will prohibit U.S. persons from participating...more
The companies were added to the Entity List for aiding Chinese military construction in the South China Sea.
Effective August 27, 2020, the Department of Commerce, Bureau of Industry and Security ("BIS") amended the Export...more
The Situation: On July 14, 2020, President Trump signed into law the Hong Kong Autonomy Act (the "HKAA"), the U.S. government's response to China's new National Security Law for Hong Kong.
The Result: The HKAA could...more
7/24/2020
/ Blocking Sanctions ,
China ,
Export Controls ,
Foreign Financial Institutions (FFI) ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
Supply Chain ,
Trump Administration ,
U.S. Treasury ,
US State Departments ,
US Trade Policies
The Situation: The U.S. Department of the Treasury ("Treasury Department") recently issued proposed regulations that will alter and in some cases expand the scope of critical technology foreign investments subject to...more
6/23/2020
/ CFIUS ,
Critical Infrastructure Sectors ,
Export Administration Regulations (EAR) ,
Export Controls ,
FIRRMA ,
Foreign Investment ,
ITAR ,
National Security ,
New Rules ,
Proposed Regulation ,
U.S. Treasury
The Situation: On April 28, 2020, the U.S. Department of Commerce's Bureau of Industry and Security ("BIS") published two final rules as well as one proposed rule amending the Export Administration Regulations ("EAR") to...more
The Situation: The U.S. Department of Justice ("DOJ") has issued guidance revising its 2016 voluntary disclosure policy to provide companies stronger incentives to voluntarily self-report apparent potentially willful trade...more
1/13/2020
/ Cooperation ,
Corporate Counsel ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
FCPA Corporate Enforcement Policy (CEP) ,
Foreign Corrupt Practices Act (FCPA) ,
New Guidance ,
Non-Prosecution Agreements ,
Self-Reporting ,
Voluntary Disclosure ,
White Collar Crimes
The Situation: The Committee on Foreign Investment in the United States ("CFIUS," or the "Committee") recently published draft regulations implementing the Foreign Investment Risk Review Modernization Act ("FIRRMA"), which...more
10/31/2019
/ Biotechnology ,
CFIUS ,
Cross-Border Transactions ,
Data Collection ,
Draft Guidance ,
Export Administration Regulations (EAR) ,
Export Controls ,
FIRRMA ,
Foreign Investment ,
ITAR ,
Life Sciences ,
National Security ,
Personal Data ,
Real Estate Transactions
Signed into law in August 2018, the Export Control Reform Act ("ECRA") significantly alters U.S. export policy by placing new emphasis and potential controls on critical technologies essential to the nation's security. As...more
On May 8, 2018, President Trump announced that the United States would cease participating in the Joint Comprehensive Plan of Action ("JCPOA"), commonly known as the Iran Deal. This will reimpose, by no later than November 5,...more
5/10/2018
/ Economic Sanctions ,
EU ,
Export Controls ,
Foreign Policy ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration