An update to our previous alert on new tariffs on Mexican and Canadian imports. Yesterday, as announced in several early February Executive Orders, the U.S. government imposed new duties on most imports from Canada and...more
The Commerce Department has issued a rule that increases export controls on AI-related items. The rule: Most of the restrictions are scheduled to take effect on May 15, 2025, although some do not come into effect until...more
China has issued the Regulation on Export Control of Dual-Use Items (the “Regulation”), which will take effect on December 1, 2024. The Regulation aims to provide clearer guidance for export control authorities’ law...more
Financial institutions face significant new compliance obligations under export control guidance issued by the Commerce Department’s Bureau of Industry and Security (BIS) last month. ...more
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 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
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 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
U.S. employers may find it confusing that hiring for certain roles can involve what seem to be competing compliance obligations. On one hand, the Immigration and Nationality Act makes it illegal for employers to make hiring...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
In light of Russia’s invasion of Ukraine and intensifying strategic competition with China, the U.S. government is prioritizing enforcement of export controls and economic sanctions in unprecedented ways. We expect higher...more
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
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
The United States, the European Union and the United Kingdom recently imposed new Russia-related sanctions in response to Russia’s continued hostilities in Ukraine...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
On December 18, 2020, the Bureau of Industry and Security (“BIS”) announced the addition of 77 new entities, including Semiconductor Manufacturing International Corporation (“SMIC”), to the Entity List. ...more
2/12/2021
/ Bureau of Industry and Security (BIS) ,
China ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Licensing Rules ,
Military End Use ,
National Security ,
Regulatory Requirements ,
Semiconductors
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
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
The U.S. government is expanding international trade restraints against Huawei Technologies Co. Ltd. (“Huawei”) and its affiliates in an effort to further restrict Huawei’s access to U.S. technologies.....more
8/20/2020
/ Bureau of Industry and Security (BIS) ,
China ,
Cybersecurity ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Adversaries ,
Foreign Policy ,
General Licenses ,
Huawei ,
National Security ,
Prohibited Transactions ,
Supply Chain ,
Telecommunications ,
Trump Administration
As noted in our recent alert, President Trump signed into law the Hong Kong Autonomy Act (“HKAA”) on July 14, 2020. On the same day, the President also issued an Executive Order on Hong Kong Normalization (the “Executive...more