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
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
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
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
Well, the Bureau of Industry and Security (BIS) waited until the summer was over, but timing may be the best part of the new export controls on Russia and Belarus (the “Rule”). Understanding the new Rule and how the old...more
9/27/2022
/ Anti-Terrorism Financing ,
Belarus ,
Biological-Weapons ,
Bureau of Industry and Security (BIS) ,
Chemical Weapons ,
Corporate Counsel ,
ECCNs ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Direct Product Rule ,
Military End Use ,
Popular ,
Russia
On May 8, 2022 (aka Mother’s Day), the Biden Administration announced yet another series of export controls and sanctions measures intended to ratchet up the costs on Russia’s economy and limit its ability to continue its war...more
5/11/2022
/ Accounting ,
Belarus ,
Blocking Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Trusts ,
U.S. Treasury ,
Ukraine
Watch Out, More Things Are Luxury Than You Think!
On March 11, 2022, the President issued Executive Order 14068 (EO 14068) Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian...more
3/15/2022
/ Belarus ,
Economic Sanctions ,
Energy Sector ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
Imports ,
Most-Favored Nations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions ,
U.S. Treasury ,
Ukraine
ArentFox Schiff sanctions advisors Kay Georgi and Matthew Tuchband talk with WorldSmart co-hosts Hunter Carter and Malcolm McNeil about greatly expanded export controls, blocking sanctions, and banking sanctions in response...more
In a coordinated effort, on March 2, 2022, the White House announced another round of broad trade controls and sanctions against Russia and now Belarus in response to Russia’s military invasion of Ukraine.
The White House...more
3/7/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
Foreign Direct Product Rule ,
Licenses ,
Military End Use ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
U.S. Commerce Department ,
Ukraine
What Are the New US Export Controls on Russia?
On February 24, 2022, the US Department of Commerce, Bureau of Industry and Security (BIS) imposed new export controls intended to restrict access to technologies and other...more
2/28/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
ECCNs ,
Economic Sanctions ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine
Responding to the Russian announcement recognizing the independence of the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine, President Biden signed Executive Order 14065 (the...more
Companies should be prepared to conduct additional due diligence for any transactions involving entities in the countries enumerated in this rule.
In an interim rule published on, January 15, 2020, the Department of...more
3/17/2021
/ Biological-Weapons ,
Bureau of Industry and Security (BIS) ,
Chemical Weapons ,
China ,
Cuba ,
Due Diligence ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Entities ,
Interim Final Rules (IFR) ,
Iran ,
North Korea ,
Nuclear Weapons ,
Russia ,
Syria ,
Trump Administration ,
U.S. Commerce Department ,
Venezuela
The Information and Communications Technology and Services (ICTS) Rule, if implemented by the Biden Administration, would significantly impact companies that have an international nexus in a number of different sectors,...more
2/2/2021
/ Biden Administration ,
China ,
Cuba ,
Department of Homeland Security (DHS) ,
Digital Service Providers ,
Executive Orders ,
FCC ,
Foreign Adversaries ,
Information and Communication Technology (ICT) ,
Interim Final Rules (IFR) ,
Iran ,
National Intelligence Agencies ,
North Korea ,
Popular ,
Russia ,
Sensitive Personal Information ,
Software ,
Supply Chain ,
Telecommunications ,
Venezuela
The US Department of Commerce, Bureau of Industry and Security (BIS) issued a final rule amending the license review policy for items on the Commerce Control List that are controlled for national security (NS) reasons and are...more
Rumors have circulated through the export community for months, and the Bureau of Industry and Security (BIS) has finally acted. In a final rule published April 28, 2020, BIS is removing License Exception Civil End-Users...more
In yet another action on April 28, 2020, the Bureau of Industry and Security (BIS) issued a final rule imposing stricter license requirements on a wide range of exports, reexports and transfers to China, Russia, or Venezuela...more
Recognizing that COVID-19 is further straining humanitarian needs in sanctioned countries and complicating compliance with economic sanctions, and perhaps also in response to reports that US sanctions are hindering COVID-19...more
4/28/2020
/ Coronavirus/COVID-19 ,
Cuba ,
Economic Sanctions ,
Executive Orders ,
FEMA ,
Humanitarian Assistance ,
Iran ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Secondary Sanctions ,
Syria ,
Ukraine ,
Venezuela
On Friday, August 2, 2019, the US State Department announced the issuance of another round of sanctions on the Russian Government in relation to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991...more