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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

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

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

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

Is the U.S. solar industry ready to prove its panels aren’t made with Uyghur forced labor?

The U.S. photovoltaic (PV) industry, solar module suppliers, manufacturers, and renewable energy developers are facing new regulatory challenges with the implementation of new legislation which has a significant impact on...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

Arming for a Trade War: The EU Proposes an Unprecedented Anti-Coercion Regulation

Scope of the Proposed Regulation - The Regulation would apply where a third country interferes in the legitimate sovereign choices of the Union or a Member State, by applying or threatening to apply measures affecting...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

Counterpunch: China Adopts Landmark Anti-Sanctions Statute to Stop U.S. Sanctions Effects Overseas

On June 10, 2021, China enacted the Anti-Foreign Sanctions Law (“AFSL”), aimed at punishing countries that impose anti-China sanctions and the companies that comply with those sanctions. The law is effective immediately, and...more

Looking Ahead on China: Engaging in Strategic Compliance through Geopolitical Analysis

A June 3, 2021 Executive Order (see our post here) designated 59 Chinese companies in which U.S. companies are prohibited from buying or selling securities. According to the Biden administration, those companies “threaten the...more

China Expands Technology Export Controls: Fighting back on TikTok and Putting Your R&D at Risk

On August 28, 2020, China took its own swing in the fight over TikTok. The blow, however, may land right in the middle of U.S.-China technology research, collaboration, and innovation. New export regulations may require...more

UPDATE: National Security Meets Teenage Dance Battles: U.S. Increases Pressure on ByteDance Sale of TikTok

The Takeaway: Severe restrictions on ByteDance’s Sale of TikTok should be a warning to media and tech companies with foreign ownership, particularly Chinese investment, to know your risks and mitigate them before the...more

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