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Overview of Section 232 Tariffs on Steel and Aluminum: What Importers Need to Know

The implementation of new 25% Section 232 duties on steel, aluminum, and certain derivatives, effective March 12, 2025, which are in addition to any special rate of duty otherwise applicable, are affecting importers globally....more

Who is Stacking the Chips: U.S. Commerce Department Launches Section 232 Investigation into Semiconductor Imports

On April 16, 2025, the Department of Commerce announced that it initiated an investigation on April 1, 2025, under Section 232 of the Trade Expansion Act, into imports of semiconductors, semiconductor manufacturing equipment...more

Blockading the Ports: U.S. Imposes 10% Global Tariff; Higher Reciprocal Tariff Rates by Country

On April 2, President Trump issued an Executive Order (EO) imposing global reciprocal tariffs (White House Fact Sheet). The EO drew enough parallels to the Smoot-Hawley Tariff Act that Trump mentioned it in his Rose Garden...more

The First Wave: U.S. Imposes Tariffs on Canada (or not?), Mexico (or not?), and China (well, yeah, probably so)

On February 1, 2025, President Trump issued three executive orders imposing tariffs on nearly all imports from Canada, Mexico, and China. However, on February 3, the President said on social media that the tariffs on Canada...more

Ticket to Ride – The Commercial Space Activity Exception and Space Tourism: Reduced Export Controls Ease Cross-Border...

You have always dreamed of going to space. All of us have at some point or another. And the only thing standing between you and that dream were overly-restrictive commodity and technology export licensing requirements on...more

At Long Last, Final Rule for Outbound Investment Regulations Published

On October 28, 2024, the U.S. Department of Treasury released a pre-publication version of its final rule containing the outbound investment regulations. The rule arrives a little over a year after Executive Order 14105,...more

The Benefits of Friends: Removing Space Export Controls for Allies (Part III of IV)

You know who your friends are. You’ve known them for a long time, you understand one another, and, importantly, you trust each other. Well, countries have friends too. Maybe country-friends have similar foreign and...more

The Commercial Industry Gets More Space: Reduced Export Controls Ease Cross-Border Collaborations (Part II of IV)

In a land before time (technologically speaking . . . so, like, the mid-nineties), the most basic software encryption functions were controlled under the U.S. International Traffic in Arms Regulations. The then-current...more

Space Rules, or . . . Space Rules!: Reduced Export Controls Ease Cross-Border Collaborations (Part I of IV)

We may imagine that a space company begins with only a few screws and some sheet metal in a garage. But regardless of its origins, not long after that early phase, that same company is likely to have a global reach....more

BIS Summer Update: Essential Reading for Your Next Beach Trip!

As we pass the midpoint of a year marked by assertive enforcement of dual use laws, the Department of Commerce’s Bureau of Industry and Security (BIS) published an updated version of its Don’t Let This Happen to You! Guide....more

Commerce Updates Boycott Requester List

On June 27, 2024, the U.S. Department of Commerce, Bureau of Industry & Security (BIS) announced its first update to the boycott requester list. The list contains entities that have been reported by a U.S. person as having...more

Now Including the Kitchen Sink: Expansion of Export Controls on Russia Adds Restrictions on Low-Level Items and Software

Last year, we published an update on BIS’s foray into prohibiting EAR99 items for export to Russia and Belarus. We noted (somewhat in jest) that kitchen sinks may one day be added. Well, that day has come. Stainless steel...more

Navigating the Solarscape: Our Handy Solar Tariffs Cheat Sheet

The solar industry is starting to get whiplash. Over the past year in particular, the industry has experienced a whirlwind of regulatory changes making solar tariffs some of the most complex tariffs in all of U.S. importing...more

China Semiconductor Export Regulations, Episode V – Updates and Corrections to the Advanced Computing and Semiconductor...

On March 29, 2024, BIS issued an interim final rule (IFR) updating and correcting its advanced computing and semiconductor regulations published in October 2023 (which we discuss here in Episode III). This marks the third...more

Department of Commerce Initiates Investigation into Chinese-Made “Connected Vehicles”: Potential Prohibitions on Certain...

On February 29, 2024, the Biden administration issued a statement addressing the national security risks to the U.S. auto industry directing the Department of Commerce to conduct an investigation into Chinese made “connected...more

Guidance to Foreign Companies on Export Controls and Sanctions: Departments of Commerce, Treasury, and Justice Issue Tri-Seal...

On Wednesday, March 6, 2024, the Department of Commerce, Department of the Treasury and Department of Justice issued another Tri-seal Compliance Note, focusing this time on the obligations of foreign based persons complying...more

China Semiconductor Export Regulations, Episode III – What a Difference a Year Makes

On Tuesday, October 17, 2023, the U.S. Bureau of Industry and Security (BIS) released a package of three rules (the 2023 Rules) targeting the Chinese semiconductor industry. The rules update the substantial semiconductor...more

New Outbound Investment Restrictions Affect China, Semiconductors, Artificial Intelligence, and Quantum Computing

On August 9, 2023, President Biden issued an Executive Order (E.O.) ordering the issuance of outbound investment restrictions. This E.O. comes after nearly a year of anticipation (as we have documented on several occasions...more

Reverse CFIUS Unveiled: Focus on China, Semiconductors, Artificial Intelligence, and Quantum Computing

On August 9, 2023, President Biden issued an Executive Order (E.O.) ordering the issuance of outbound investment restrictions. This E.O. comes after nearly a year of anticipation (as we have documented on several occasions...more

Everything but the Kitchen Sink (and Maybe That Too!): New Export Controls on Russia Cover Whole Categories of Low-Level...

The United States and its allies are aiming to choke off the supplies that support the last vestiges of Russian industry. On May 19, 2023, the Bureau of Industry and Security (BIS) released new regulations implementing...more

Biden Veto Maintains Solar Tariff Moratorium

On May 16, 2023, President Joseph Biden vetoed the Congressional Review Act (CRA) resolution that would have nullified the temporary moratorium on the collection of antidumping and countervailing (AD/CVD) duties on imports of...more

Watching the Detectives: Export Control Enforcement Trends Upward

Between Russia’s invasion of Ukraine and growing U.S. tensions with China, U.S. export controls are in the spotlight like never before. As if regulators have not already made it clear enough, recent statements and actions...more

OFAC Finds Digital Assets Trading Platform in Violation of Sanctions

On March 31, 2023, the Office of Foreign Assets Control (OFAC) announced a $72,230.32 settlement agreement with Uphold HQ Inc. (Uphold), a global multi-asset digital trading platform, in connection with 152 apparent...more

Friday Development: New Sanctions and Export Controls to Address Russia’s Ongoing Aggression in Ukraine (Including the use of...

In response to Russia’s ongoing aggression in Ukraine, both the United States and the European Union have imposed additional sanctions and further restricted exports to Russia and Iran. These new controls span many...more

Potential Sanctions for Alleged Intellectual Property Theft on the Horizon?

On January 5, 2023, President Biden signed into law S. 1294, the “Protecting American Intellectual Property Act of 2022”. The Act requires the president to report to Congress and impose sanctions on any foreign person or...more

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