The U.S. Department of Commerce and U.S. Department of State have been continuously easing restrictions on export-controlled trade between the United States, United Kingdom and Australia to foster technological innovation...more
8/29/2024
/ Amended Rules ,
Artificial Intelligence ,
Australia ,
CFIUS ,
Comment Period ,
Cybersecurity ,
Defense Sector ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Innovative Technology ,
Interim Final Rules (IFR) ,
ITAR ,
Military Goods ,
National Security ,
Proposed Rules ,
U.S. Commerce Department ,
UK ,
US State Departments
Differences in law as well as cultural differences can prolong international aircraft transactions. Assembling a good team of legal and technical professionals, as well as an aircraft broker familiar with international...more
9/29/2023
/ Aircraft ,
Aviation Industry ,
Contract Terms ,
Cross-Border Transactions ,
Due Diligence ,
Exports ,
Federal Aviation Administration (FAA) ,
Imports ,
Know Your Customers ,
Letters of Intent ,
Purchase Agreement ,
Regulatory Requirements
The U.S. Department of Justice (DOJ), Department of Commerce's Bureau of Industry and Security (BIS) and Department of the Treasury's Office of Foreign Assets Control (OFAC) on July 26, 2023, issued a Tri-Seal Compliance Note...more
8/2/2023
/ Bureau of Industry and Security (BIS) ,
China ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Authority ,
Export Controls ,
Exports ,
Iran ,
Joint Policy Statements ,
Joint Statements ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
Self-Reporting
As an update to an earlier Holland & Knight alert on the same topic, the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) has published another determination pursuant to Executive Order 14071 expanding...more
2/8/2023
/ Australia ,
Biden Administration ,
Crude Oil ,
Economic Sanctions ,
EU ,
Executive Orders ,
Exports ,
G7 ,
Maritime Transport ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Petroleum ,
Russia ,
Tariffs ,
Ukraine
Update: This Holland & Knight alert has been updated on Sept. 25, 2022, with additional information. In plain English, anytime an aircraft departs the United States, this is an "export" and will fall in one of two "buckets":...more
9/27/2022
/ Aircraft ,
Aircraft Sales ,
Aviation Industry ,
Customs and Border Protection ,
Electronic Filing ,
Export Controls ,
Exports ,
Federal Aviation Administration (FAA) ,
Filing Requirements ,
Foreign Entities ,
Registration Requirement
Please note: This Holland & Knight alert has been updated on Sept. 13, 2021, with additional information.
In plain English, anytime an aircraft departs the United States, this is an "export" and will fall in one of two...more
9/14/2021
/ Aircraft ,
Aircraft Sales ,
Aviation Industry ,
Bureau of Industry and Security (BIS) ,
Customs and Border Protection ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exporters ,
Exports ,
Federal Aviation Administration (FAA) ,
Filing Requirements ,
ITAR
There are two common types of aircraft exports: 1) permanent exports – where the aircraft is physically exported (i.e., flown) from the U.S. as part of a sale, lease or transfer of possession and control to a foreign person,...more
2/23/2021
/ Aircraft ,
Aircraft Sales ,
Aviation Industry ,
Bureau of Industry and Security (BIS) ,
Customs and Border Protection ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exporters ,
Exports ,
Filing Requirements ,
ITAR
The Federal Emergency Management Agency (FEMA) on April 8, 2020, released an advance copy of a temporary rule banning exportation of five types of Personal Protective Equipment (PPE) from the United States without its...more
The U.S. Office of Foreign Assets Control (OFAC) on Sept. 25, 2019, designated COSCO Shipping Tanker (Dalian) Co. Ltd. (COSCO Dalian), Kunlun Shipping Company Ltd., and certain other entities and individuals as Specially...more
10/8/2019
/ China ,
Controlled Foreign Corporations ,
Economic Sanctions ,
Executive Orders ,
Exports ,
Iran Sanctions ,
Maritime Transport ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Petroleum ,
Risk Mitigation ,
Safe Harbors ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
Vessels
• President Donald Trump saying at the recent G20 Summit in Japan that American companies could keep selling products to Huawei Technologies Co. Ltd. (Huawei) was another installment in the drama surrounding the Chinese tech...more
7/17/2019
/ Bureau of Industry and Security (BIS) ,
China ,
Entity List ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Adversaries ,
Foreign Policy ,
General Licenses ,
Huawei ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Sanction Violations ,
Technology Sector ,
Telecommunications ,
Trade Relations ,
Trade Wars ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies
• The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) revoked certain Iran-related "general licenses" that allowed U.S. and U.S.-owned foreign entities to engage in certain transactions and...more
On May 8, President Trump announced that the United States is withdrawing from the multilateral nuclear accord with Iran known as the Joint Comprehensive Plan of Action (JCPOA). The U.S. will reimpose sanctions suspended...more
5/11/2018
/ Aircraft Sales ,
Aviation Industry ,
Cross-Border Transactions ,
Economic Sanctions ,
Exports ,
Foreign Banks ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
Foreign Subsidiaries ,
General Licenses ,
Iran ,
Joint Comprehensive Plan of Action (JCPOA) ,
Lessor ,
Manufacturers ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration
Executive Order Relating to the Crimea Region -
On Dec. 19, 2014, in a step coordinated with similar sanctions imposed by the European Union (EU), President Obama issued a new Executive Order targeting the Crimea...more
12/29/2014
/ Banking Sector ,
Barack Obama ,
Crimea ,
Defense Sector ,
Energy Sector ,
Executive Orders ,
Exports ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanctions ,
SDN List ,
UFSA ,
Ukraine
New rules implementing export control reforms become effective October 15, 2013. The keystone of these reform efforts is to transfer jurisdiction of less sensitive military items currently controlled under the International...more
The United States continues to impose additional layers of sanctions on Iran. The rate of change and complexity of U.S. sanctions laws present challenges, particularly where these sanctions have extraterritorial effect on the...more
1/16/2013
/ Disclosure Requirements ,
Export Controls ,
Exports ,
Foreign Banks ,
Foreign Exchanges ,
IFCPA ,
Iran Sanctions ,
Iran Threat Reduction and Syria Human Rights Act ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Subsidiaries