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SBA May Eliminate Self-Certification of SDVOSB Status for Federal Contracting

On June 6, 2024, the US Small Business Administration (SBA) published a direct final rule that would eliminate self-certification of service-disabled veteran-owned small businesses (SDVOSB) status for purposes of agency...more

New License Exception Authorizes Exports of Previously Restricted Medical Devices and Related Items to Russia, Belarus, Occupied...

The US Department of Commerce’s Bureau of Industry and Security (BIS) added a new License Exception for Medical Devices (License Exception MED), effective April 29, 2024, authorizing exports, reexports and transfers of...more

New US Law Doubles Statute of Limitations for Sanctions Violations

On April 24, 2024, President Joe Biden signed into law HR 815, which primarily provides supplemental emergency appropriations relating to ongoing conflicts in Ukraine, Israel and Taiwan. Although principally focused on an...more

NSD’s Revised Enforcement Policy for Business Organizations Incentivizes Voluntary Self-Disclosures in M&A Context

Companies engaged in mergers & acquisitions activities should take note of the revised voluntary self-disclosure policy (VSD Policy) of the National Security Division (NSD) of the US Department of Justice, released on March...more

Tri-Seal Compliance Note Highlights Broad Reach of US Trade Controls, Obligations of Non-US Persons

On 6 March 2024, the US Department of Commerce, Department of the Treasury and Department of Justice issued a Tri-Seal Compliance Note (compliance note) advising foreign-based companies and individuals to assess their...more

US Government ‘Strike Force’ to Block Foreign Adversaries From Obtaining Disruptive Technologies

The federal government sent another big signal that it’s stepping up efforts to keep cutting-edge, dual-use and military technologies out of the hands of adversarial foreign governments when it announced the launch of the...more

Export Control Reminder: Encryption Reporting Deadline Is February 1, 2023

The deadline for submitting reports regarding certain exports of encryption items under the US Export Administration Regulations (EAR) is February 1, 2023. Two types of reports are subject to the deadline...more

Export Control Reminder: Semiannual Encryption Reporting Deadline Is August 1, 2022

August 1, 2022 is the deadline for submitting semiannual reports for certain encryption items exported or re-exported between January 1 and June 30, 2022, pursuant to paragraphs (b)(2) and (b)(3)(iii) of License Exception ENC...more

8/1/2022  /  ECCNs , Encryption , Export Controls , Exports

War and Office of Foreign Assets Control Exclusions: Insurance Policy Language Matters

Nearly two weeks into the Russian invasion of Ukraine, numerous companies are focused on how the war might impact their business, including their insurance coverage. This advisory provides a high-level overview of two types...more

Evolving US, UK and EU Sanctions and Export Controls Target Russia for Ukraine Invasion

In response to Russia’s invasion of Ukraine in February 2022, the United States, with support from its allies including the United Kingdom and the European Union, has imposed a complex mix of financial sanctions and export...more

US Commerce Department Adds 33 Chinese Entities to Unverified List

On February 8, 2022, the US Department of Commerce’s Bureau of Industry and Security (BIS) added 33 Chinese entities to the agency’s Unverified List (UVL). The UVL does not fully prohibit transactions with the designated...more

Export Control Reminder: Encryption Reporting Deadline Is February 1, 2022

The deadline for submitting reports regarding certain exports of encryption items under the US Export Administration Regulations (EAR) is February 1, 2022. Two types of reports are subject to the deadline...more

OFAC Issues Sanctions Compliance Guidance for Virtual Currency Industry

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued Sanctions Compliance Guidance for the Virtual Currency Industry. The guidance published on October 15, 2021, outlines OFAC’s...more

Alert - Export Control Reminder: Encryption Reporting Deadline February 1, 2021

February 1, 2021, is the deadline for submitting reports regarding certain exports of encryption items under the US Export Administration Regulations (EAR). Two types of reports are subject to the deadline: 1. Annual...more

Alert: US Government Imposes Export Restrictions on SMIC, DJI and 75 Other Entities

The US Department of Commerce’s Bureau of Industry and Security has issued a Final Rule adding 77 companies to the Entity List, a restricted party list that identifies foreign persons that engage in activities contrary to US...more

Alert: CFIUS Final Rule Leverages Export Control Principles to Redefine Mandatory Filing Requirements

On September 15, 2020, the US Department of the Treasury issued a Final Rule comprising the latest regulation in an ongoing effort to reform the way the United States reviews and confronts the national security implications...more

Alert: Export Control Reminder: Semi-Annual Encryption Reporting Deadline August 1

August 1, 2020, is the deadline for submitting semi-annual reports for certain encryption items exported or re-exported between January 1 and June 30, 2020, pursuant to paragraphs (b)(2) and (b)(3)(iii) of License Exception...more

Alert: CFIUS Update: Final Regulations Implement FIRRMA

The US Department of the Treasury has issued two final regulations implementing the Foreign Investment Risk Review Modernization Act of 2018 ("FIRRMA"). The final regulations broadly expand the jurisdiction of the Committee...more

Alert: Export Control Reminder: Encryption Reporting Deadline February 1, 2020

The new year brings with it the reporting deadlines for exports of encryption items under the US Export Administration Regulations. February 1, 2020, is the deadline for submitting annual self-classification reports for...more

Alert: Commerce Zooms in on AI Software for Geospatial Imagery Analysis

On Monday, January 6, 2020, the US Department of Commerce's Bureau of Industry and Security published an interim rule that places additional export control restrictions under the Export Administration Regulations on certain...more

Alert: Commerce Department Extends Huawei Reprieve, Adds 46 Affiliates

On August 21, the Commerce Department's Bureau of Industry and Security (BIS) published an extension to the Huawei temporary general license from May, extending it through November 18 and adding 46 non-US affiliates of Huawei...more

Alert: Export Control Reminder: Semi-Annual Encryption Reporting Deadline 8/1/19

August 1, 2019, is the deadline for submitting semi-annual reports for certain ENC Restricted encryption items exported or re-exported between January 1 and June 30, 2019, pursuant to paragraphs (b)(2) and (b)(3)(iii) of...more

Alert: Executive Order Restricts Access to US Telecom Markets for Equipment, Services That Impose Security Risks

On May 15, President Donald Trump signed an executive order starting the process for banning the importation, sale and use of equipment and technology in the US as a response to potential security risks. Although this order...more

Alert: Export Control Reminder: Encryption Reporting Deadline 2/1/2019

The new year brings with it the reporting deadlines for exports of encryption items under the US Export Administration Regulations. February 1, 2019, is the deadline for submitting annual self-classification reports for...more

Alert: Commerce Identifies Emerging Technologies for Potential New Export Control Restrictions and CFIUS Review

The Department of Commerce's Bureau of Industry and Security has published an advance notice of proposed rulemaking seeking public comments on a draft list of various emerging technologies that may soon be subject to...more

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