On September 6, 2024, the Bureau of Industry and Security (BIS) of the U.S. Commerce Department issued an interim final rule expanding export controls on certain emerging technologies: Quantum Computing: Quantum computers,...more
The U.S. Department of the Treasury proposed regulations on June 21, 2024, that would prohibit certain outbound investments by U.S. persons in Chinese companies focused on semiconductors and microelectronics, quantum...more
The United States has substantially expanded economic sanctions and export controls targeting Russia and Belarus, imposing new restrictions that could have a major impact on companies with business activities in or relating...more
With a flurry of recent activity, the U.S. government is administering or considering import duties and quotas on imports of solar energy equipment in three areas: The solar module tariff-rate quota under the “Section 201”...more
The Committee on Foreign Investment in the United States (CFIUS) has taken another significant step in transforming from a limited jurisdiction interagency committee that primarily reviewed voluntary filings into a body with...more
On October 17, 2023, the U.S. Commerce Department’s Bureau of Industry Security (BIS) issued revised export control regulations intended to impede China’s efforts to obtain and produce advanced semiconductors. The new steps...more
The Committee on Foreign Investment in the United States (CFIUS) reportedly observed limits on its authority in a recent case to examine and potentially disturb foreign investment transactions for national security reasons....more
The United States has strengthened economic sanctions and export controls targeting Russia, following through on commitments made at a G7 summit this month. The EU and UK also plan to substantially expand measures targeting...more
On April 19, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a $300 million civil penalty on Seagate Technology LLC, a U.S. supplier of data-storage products. BIS found that...more
On December 2, 2022, the U.S. Department of Commerce (“Commerce”) issued preliminary affirmative determinations of circumvention with respect to crystalline silicon photovoltaic (“CSPV”) cells and modules exported to the...more
12/6/2022
/ Anti-Dumping Duty ,
Cambodia ,
China ,
Countervailing Duties ,
Exporters ,
Imports ,
Malaysia ,
Plastic Solar Cells ,
Solar Panels ,
Tariffs ,
Thailand ,
U.S. Commerce Department ,
US Trade Policies ,
Vietnam ,
Waivers
On October 7, 2022, the U.S. Commerce Department’s Bureau of Industry Security (“BIS”) released new export control regulations (the “New Regulations”) that intensify and complicate U.S. and non-U.S. companies’ international...more
On August 22, the U.S. Department of Commerce (“Commerce”) postponed its preliminary determinations in the solar panel antidumping and countervailing duty (“AD/CVD”) circumvention proceeding by 90 days. The preliminary...more
The Uyghur Forced Labor Prevention Act (the “Uyghur Act”) came into effect on June 21, 2022. As we described previously, the Uyghur Act establishes a rebuttable presumption that goods mined, produced, or manufactured, in...more
On June 6, 2022, the Biden Administration announced its intention to waive collection of antidumping (“AD”) and countervailing (“CVD”) duties on imports of crystalline silicon photovoltaic (“CSPV”) cells and modules from...more
As part of its continuing response to Russia’s ongoing hostilities in Ukraine, the United States recently imposed additional sanctions and export controls targeting Russia...more
On May 2, the U.S. Department of Commerce issued a memorandum to update litigation parties on developments in the on-going solar cell and panel circumvention proceeding...more
The United States and its allies continue to ramp up pressure on Russia and Belarus in response to Russia’s continued hostilities in Ukraine. In this alert, we describe the latest export, import, and investment bans and...more
The U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) has adjusted U.S. export controls in ways that dramatically limit unlicensed supply to Russia or Belarus of many types of software with encryption...more
Building on the “first tranche” of sanctions announced on February 22, 2022 described in our prior alert, the United States, the EU, the UK, and their allies have imposed (or announced the imposition of) additional...more
3/1/2022
/ Blocking Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
Financial Transactions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SWIFT ,
Ukraine ,
Virtual Currency
Every week, scores of U.S. companies are sold to foreign investors or execute equity financing transactions involving foreign investors. Parties to these transactions must assess whether they are legally required to file...more
On October 21, 2021, the Commerce Department’s Bureau of Industry and Security (“BIS”) published a rule that will restrict some exports, reexports, and other overseas transfers of equipment, software, and technology...more
In March 2021, three federal agencies promulgated international trade restraints as part of the Biden Administration’s response to alleged mistreatment of Russian opposition leader Alexey Navalny in 2020. Specifically, the...more
3/31/2021
/ Arms Embargo ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
CAATSA ,
Economic Sanctions ,
Energy Projects ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Infrastructure ,
ITAR ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
Trade Restrictions ,
US Trade Policies ,
Vessels
In response to a U.S. government consensus that trade with China involves grave national security risks, the Trump Administration promulgated a broad series of China-directed export controls, economic sanctions and import...more
1/28/2021
/ Biden Administration ,
Blocking Statutes ,
China ,
Economic Sanctions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Human Rights ,
Infrastructure ,
Military End Use ,
Regulatory Reform ,
US Trade Policies
Last week, the Department of Commerce took steps to implement sanctions targeting China’s mobile applications WeChat, owned by Tencent Holdings Ltd. (“WeChat Sanctions”), and TikTok, owned by ByteDance Ltd. (“ByteDance”)...more
As anticipated in our prior alert, yesterday the Committee on Foreign Investment in the United States (“CFIUS”) published a final rule that ties CFIUS’s mandatory filing requirement for certain “critical technology”...more
9/16/2020
/ CFIUS ,
Covered Transactions ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Filing Requirements ,
FIRRMA ,
Foreign Investment ,
ITAR ,
National Security ,
Regulatory Requirements