It’s hard not to experience whiplash with export controls recently. A little over a month ago, the Bureau of Industry and Security (BIS) announced the new Affiliates Rule, which took effect immediately on September 29....more
The Bureau of Industry and Security (BIS) updated its Entity List FAQs, providing some additional guidance about the “Affiliates Rule” that came into effect on September 29....more
10/8/2025
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Corporate Counsel ,
Enforcement ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Branch Offices ,
New Guidance ,
Risk Management ,
U.S. Commerce Department
Welcome to the September 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more
9/17/2025
/ Customs and Border Protection ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
False Claims Act (FCA) ,
International Trade ,
Popular ,
Section 232 ,
Tariffs ,
Trump Administration ,
Uyghur Forced Labor Prevention Act (UFLPA)
After a three month wait, the US Department of Commerce’s Bureau of Industry and Security (BIS) has finally caught up with the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) in relaxing restrictions...more
9/5/2025
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Syria ,
Trade Policy ,
U.S. Commerce Department
Welcome to the August 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more
8/19/2025
/ Artificial Intelligence ,
CFIUS ,
China ,
Compliance ,
Country of Origin ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Export Controls ,
Fraud ,
International Trade ,
Popular ,
Tariffs ,
Trump Administration
On July 22, the US Senate passed the Maintaining American Superiority by Improving Export Control Transparency Act (the Bill), sending it to President Trump for his signature....more
On May 23, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 25, “Authorizing Transactions Prohibited by the Syrian Sanctions Regulations or Involving Certain...more
6/3/2025
/ Corporate Counsel ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Publicly-Traded Companies ,
Regulatory Requirements ,
Reporting Requirements ,
Syria ,
U.S. Treasury
Welcome to the April 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more
4/11/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Country of Origin ,
Customs and Border Protection ,
Economic Sanctions ,
Enforcement Actions ,
Executive Orders ,
Export Controls ,
False Claims Act (FCA) ,
Forced Labor ,
Harmonized Tariff Schedule of the United States (HTSUS) ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Supply Chain ,
Tariffs ,
Trade Wars ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
President Trump’s first months in office have been busy, but, in the export control world, we have been grateful for a brief respite from the mind-bending, hundreds-of-pages-long, industry-changing rules that the US...more
The US Department of Commerce’s Bureau of Industry and Security (BIS) introduced its long-anticipated (some would say dreaded) Framework for Artificial Intelligence Diffusion (the AI Diffusion Rule) on January 15. Highlights...more
1/17/2025
/ America Invents Act ,
Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Department of Energy (DOE) ,
Export Administration Regulations (EAR) ,
Export Controls ,
Final Rules ,
Foreign Direct Product Rule ,
Innovative Technology ,
Interim Final Rules (IFR) ,
National Security ,
Semiconductors ,
Technology Sector
Welcome to the October 2024 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more
10/18/2024
/ Aluminum Sales ,
Automotive Industry ,
Bureau of Industry and Security (BIS) ,
China ,
Compliance ,
E-Commerce ,
Fashion Industry ,
Forced Labor ,
Foreign Trade Zones ,
Importers ,
Manufacturers ,
NAFTA ,
Proposed Rules ,
Retailers ,
Russia ,
Supply Chain ,
Technology Sector ,
Trade Act of 1974 ,
Trade Relations ,
U.S. Customs ,
United States-Mexico-Canada Agreement (USMCA) ,
USTR ,
Uyghur Forced Labor Prevention Act (UFLPA)
Welcome to the September 2024 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more
9/17/2024
/ Aluminum Sales ,
Anti-Subsidies ,
Canada ,
Child Labor ,
China ,
Countervailing Duties ,
Customs and Border Protection ,
Department of Labor (DOL) ,
ECCNs ,
Electric Vehicles ,
Enforcement ,
Export Controls ,
False Claims Act (FCA) ,
Forced Labor ,
Fraud ,
Imports ,
ITAR ,
Manufacturers ,
Popular ,
Risk Mitigation ,
Section 301 ,
Solar Panels ,
Steel Industry ,
Surtax ,
Tariffs ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies ,
USTR ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Whistleblowers
On July 29, the Directorate of Defense Trade Controls (DDTC) of the US Department of State proposed a new definition of the term “defense service.”
The International Traffic in Arms Regulations (ITAR) imposes a license...more
On July 29, the US government proposed big changes to rules about supporting or exporting to foreign military, intelligence, and security entities.
The US Department of Commerce’s Bureau of Industry and Security (BIS) is...more
Welcome to the July 2024 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more
7/16/2024
/ Aluminum Sales ,
Chevron Deference ,
Chevron v NRDC ,
Customs and Border Protection ,
Economic Sanctions ,
Enforcement ,
Export Controls ,
Forced Labor ,
Foreign Investment ,
Imports ,
International Trade Commission (ITC) ,
Loper Bright Enterprises v Raimondo ,
Mexico ,
Proposed Rules ,
Russia ,
SCOTUS ,
Steel Industry ,
U.S. Treasury
Three US agencies – the US Department of Commerce, Bureau of Industry and Security (BIS), the US Department of the Treasury, Office of Foreign Assets Control (OFAC), and the US Department of State – took new actions on June...more
6/17/2024
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Harmonization Rules ,
Infrastructure ,
Licenses ,
Licensing Rules ,
Mobile Devices ,
Office of Foreign Assets Control (OFAC) ,
Personal Information ,
Popular ,
Russia ,
Savings Clause ,
SDN List ,
Software ,
US State Departments
The US Government just placed Australia and the United Kingdom (UK) in nearly the same position as Canada for dual-use exports under the Export Administration Regulations (EAR) and is poised to go even further with a proposed...more
5/8/2024
/ Australia ,
Commerce Control List ,
Corporate Counsel ,
Directorate of Defense Trade Controls (DDTC) ,
Dual Use Goods ,
Export Administration Regulations (EAR) ,
Exports ,
ITAR ,
NISPOM ,
Popular ,
Proposed Regulation ,
UK
License Exception MED, published by the US Department of Commerce’s Bureau of Industry and Security (BIS) on April 25, authorizes the export, reexport, or in-country transfer of EAR99 “medical devices” to non-military...more
Two years after the start of Russia’s war in Ukraine and one week after the death of opposition politician and anticorruption activist Aleksey Navalny, the US government announced a new raft of sanctions and export controls...more
On January 25, almost two years after Russia’s further invasion of Ukraine, the US Department of Commerce, Bureau of Industry and Security (BIS) issued a final rule (the Rule) strengthening existing export controls relating...more
1/31/2024
/ Aircraft ,
Belarus ,
Bureau of Industry and Security (BIS) ,
Drones ,
ECCNs ,
Export Administration Regulations (EAR) ,
Export Controls ,
Final Rules ,
Licensing Rules ,
Military Conflict ,
Russia ,
Tariffs ,
U.S. Commerce Department
Just in case you were starting to get comfortable with last year’s massive raft of regulations on the advanced computing, supercomputer, and semiconductor industries in China, the US Department of Commerce, Bureau of Industry...more
During the G7 meeting in Japan on May 19, 2023, the US Department of Commerce’s Bureau of Industry and Security (BIS) published two new rules aimed at further restricting Russia’s ability to obtain items needed to support its...more
6/7/2023
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Export Administration Regulations (EAR) ,
Export Controls ,
G7 ,
Office of Foreign Assets Control (OFAC) ,
Petroleum ,
Russia ,
SDN List ,
U.S. Commerce Department ,
Ukraine
Voluntary No More -
In taking steps to take the “voluntary” out of voluntary disclosure, Assistant Secretary of US Export Enforcement Matthew Axelrod issued another memorandum on April 18, 2023, following on his June 2022...more
On Friday, February 24, the one-year anniversary of Russia’s further invasion into Ukraine, President Biden, the Office of Foreign Assets Control (OFAC), the US Department of State, and the US Department of Commerce, Bureau...more
3/1/2023
/ Banking Sector ,
Belarus ,
Bureau of Industry and Security (BIS) ,
Duties ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Huawei ,
Imports ,
Metals ,
Mining ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Tariffs
On October 28, 2022, the US Department of Commerce, Bureau of Industry (BIS) issued FAQs on the new semiconductor regulations. The FAQs are short and relatively clear (thank you!) even if they were released on a Friday...more