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Footnote Frenzy: Charting Out Commerce’s Proposed Expanded US Person and End Use Export Controls and Facial Recognition Controls

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

Commerce Tidies Up the Russia/Belarus Export Controls and Adds Aircraft and Drones (HTS Ch 88) to Its License Requirements

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

Stopping Just Short of the Kitchen Sink, USG Requires Licenses for Exports of Entire HTS Chapters to Russia

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

US Sanctions Belarus and Piles on More Russian Sanctions: What You Need to Know

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

Biden Puts Semiconductor Supply Chains Under Microscope

In late September, the Biden Administration took a variety of actions to address the ongoing global semiconductor shortage and the various supply chain disruptions caused by the COVID-19 pandemic. That includes convening a...more

Commerce Department Signals Tough Approach on China Under Controversial Trump Tech Supply Chain EO

The subpoena issuance suggests that the Biden Administration will continue the US Government’s assertive approach to China. The US Department of Commerce, on March 17, 2021, issued subpoenas on multiple Chinese companies...more

Sleeper Trump Rule on ‘Military-Intelligence End Uses or Users’ Goes Into Effect

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

US Sanctions on Chinese Apparel Companies for Forced Labor Hit Retail Supply Chains

There is a risk that garments made from cotton produced by XPCC could be subject to a Customs and Border Protection withhold release orders. Fashion and luxury goods companies need to be concerned about the recent...more

US Government Hurls Another Export Control Grenade at Huawei

On Friday, May 15, 2020, the Department of Commerce and the Bureau of Industry and Security (BIS) revised an arcane export control rule that imposes US export controls on foreign-origin products (hardware, software, and...more

ITAR Defense Controls Catches Up to Modern IT, Allowing Exporters to Use Encryption to Protect Defense Technology on the Cloud

The good news is that, for the most part, State resisted the temptation to do something just a little different in the ITAR regulation, so the joint Commerce-State solution works. The chart below provides a quick side-by-side...more

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