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A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part III

The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and...more

A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part II

The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and...more

A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part I

The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and...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

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

OFAC Tightens Russia Sanctions; BIS Cracks Down on Diversion

On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new measures targeting Russia’s financial infrastructure, including: 1. Expanding the scope of financial sanctions:...more

Technology Protection is a Core National Security Priority: BIS Strengthens Its Policy on Disclosures

Recently, the Department of Commerce issued a memo, emphasizing that “technology protection is a core national security priority” and how companies that choose not to disclose significant violations of export regulations may...more

Breaking the Link – New Developments on U.S. Licenses for Exports to Huawei

It looks like the licensing restrictions on Huawei are trickling into effect. Our sources indicate that, as early as February 27, all license applications for exports or transfers involving Huawei which were pending with...more

Tightening the Cordon – U.S. Restricts Licensing Policy and Adds Allies to Technology Controls

On Monday, February 13, 2023, the U.S. government will officially issue a stricter policy of denial for providing lower-tech items to Huawei. Technological containment continues as the Netherlands and Japan move to impose...more

China Semiconductor Export Regulations, Episode I – Counting Your Chips Carefully

The Announcement On Friday, October 7, 2022, the U.S. Bureau of Industry and Security (BIS) released for public inspection (available ...) one hundred forty pages of regulations (which we’ll call “the Regulation” here) that...more

Further Export Controls on Semiconductor Technology for China coming this Week

On Thursday, the Biden administration will announce new restrictions preventing China from accessing advanced U.S. semiconductor technology. According to reports, the U.S. Department of Commerce, Bureau of Industry and...more

Russian Risk: Transactions with Russian Banks and Exports to Russia Create Greatest Exposure Under New U.S. Ukraine-Related...

Updated as of February 25, 2022 - Key Takeaways of OFAC (Treasury) and BIS (Commerce) Actions - Major Russian Banks Blocked from the U.S. Financial System. Six major Russian banks — VEB, Promsvyazbank (PSB), VTB Bank,...more

Verify, Then Trust: Commerce Adds 33 Parties in China to Unverified List

On February 8, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a Final Rule amending the Export Administration Regulations to add 33 Chinese parties, to the Unverified List (UVL)...more

Clean Energy’s Messy Problem: The Solar Industry, the U.S. Government, and the Complex Task of Combatting Forced Labor

This is the first of three articles on the Solar Industry and Forced Labor. Here we focus on regulation. Articles in the coming weeks will focus on issues facing importers and their suppliers, and on investors and their...more

U.S. Imposes Sanctions Measures Targeting Myanmar Military Government

On February 1, 2021, the Myanmar military overthrew the country’s democratically elected government and installed an army general as head of state, with a cadre of military officials and their allies running the government. ...more

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