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E(U)xterritoriality of EU Sanctions: The No Russia Clause

The EU is going extraterritorial, and it is doing so through private contract. It is a pretty neat trick. As a general rule, EU regulations do not apply extraterritorially. This policy is a bit pointed, intended to stand...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

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

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

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

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

Updated as of February 25, 2022 - Key Takeaways of EU and UK Recent Actions Against Russia and Ukraine Breakaway Regions - The EU adopted the first tranche of sanctions restrictions targeting financial institutions, other...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

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

Lend Me Your EARs: CFIUS Makes Export Controls a Trigger for Mandatory Filings

On October 15, 2020, CFIUS will officially tie mandatory filings to U.S. export control regimes, including the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR). While that...more

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