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Significant New U.S. Person and Other Export Controls Proposed Regarding Military, Intelligence, and Security End Users

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has published proposed amendments to the Export Administration Regulations (EAR) that would significantly expand the scope of the export controls over...more

DOJ Focuses on Corporate Crime Involving Sanctions Evasion, Export Controls Violations and Similar Economic Crimes

Key Points - On March 2, 2023, DOJ announced that its NSD would hire more than 25 new prosecutors to investigate and prosecute sanctions evasion, export controls violations and similar economic crimes. Consistent with...more

2022 Economic Sanctions Year in Review and Outlook for 2023

Introduction - In 2022, the United States, European Union (EU) and United Kingdom, along with a significant number of other partners and allies, imposed an unprecedented number of economic, financial and trade sanctions...more

Russia, China, Semiconductors and Reimagining National Security: US Export Controls 2022 Year in Review

The volume and impact of changes to United States export control regulations in 2022 were unprecedented, and we expect 2023 will likely bring additional changes. This alert provides a summary of key changes, themes and...more

Commerce Department Publishes Updated Guidance on Antiboycott Enforcement Policies

Background - U.S. antiboycott laws, which are divided into two separate regimes administered by the U.S. Department of Commerce and the U.S. Department of the Treasury, prohibit U.S. persons from participating in foreign...more

BIS Announces Significant Changes to How It Administers Unverified and Entity Lists

Key Points - BIS amended the EAR to add a new criterion for placing a party on the Entity List: a sustained lack of cooperation by the host government to schedule and facilitate the completion of an end-use check of an...more

U.S. Government Imposes Expansive, Novel and Plurilateral Export Controls Against Russia and Belarus

Key Points - As part of highly coordinated U.S. government and allied and partner country responses to Russia’s further invasion of Ukraine, and Belarus’ enabling of it, BIS imposed on February 24, 2022, and March 2,...more

US Government Clarifies, Reorganizes and Renames Descriptions of How Foreign-Produced Items Outside the United States Are Subject...

Key Points - The U.S. Department of Commerce has reorganized and clarified the regulations describing when foreign-produced items outside the United States are and are not subject to the licensing and other obligations of...more

Ukraine-Russia Crisis: Possible New Sanctions and Export Controls on Russia and Potential Implications for U.S. and Non-U.S....

Key Points - The United States, European Union, United Kingdom and other U.S. allies are currently considering a range of severe economic measures against Russia to impose in the event of a Russian military incursion into...more

Treasury Publishes U.S. Sanctions Policy Review and Framework for Future Action

On October 18, 2021, the U.S. Treasury Department released a long awaited report on its first of its kind “top to bottom” review of U.S. economic and financial sanctions. The report does not make or recommend any immediate or...more

The New PRC Anti-Foreign Sanctions Law

On June 10, 2021, the 29th session of the Standing Committee of the 13th National People’s Congress ("NPC") adopted China’s new Anti-Foreign Sanctions Law,1which took immediate effect. The new law provides legal grounds for...more

Licenses for Exports to Russia Related to Commercial Space Launches Must be Granted by September 1, 2021

As part of the United States’ response to Russia’s use of chemical weapons against Russian opposition figure Aleksey Navalny, the U.S. State Department applied a policy of denial to licenses and other approvals for exports to...more

Treasury Removes UAE from List of Countries Requiring Cooperation with an International Boycott

Key Points - On April 8, the Treasury Department removed the UAE from its list of countries requiring cooperation with an international boycott, thereby removing the UAE from the scope of the Treasury Department’s...more

BIS Announces the Elimination of License Exception CIV, Expanded Licensing Requirements on Exports to Chinese, Russian, and...

- On April 28, 2020, the Bureau of Industry and Security of the U.S. Department of Commerce announced changes to the Export Administration Regulations (EAR) through three notices published on the Federal Register. The changes...more

DDTC Publishes New FAQs on Activities by Non-U.S. Persons After the Expiration of an Agreement

- On March 31, 2020, DDTC published five new FAQs on activities that non-U.S. persons may engage in following the expiration of a Technical Assistance Agreement (TAA) or Manufacturing Licensing Agreement (MLA). - The FAQs...more

OFAC Sanctions Key Rosneft Subsidiary and Executive for Operating in the Oil Sector of Venezuela

- On February 18, 2020, OFAC designated Rosneft Trading, S.A. (Rosneft Trading), a subsidiary of Russia-based Open Joint-Stock Company Rosneft Oil Company (Rosneft Oil Company), and its president, Didier Casimiro, on the SDN...more

Commerce Extends and Revises Temporary General License Authorizing Specified Transactions with Huawei and Its Affiliates; Adds...

• The Commerce Department’s Bureau of Industry and Security (BIS) has added 46 additional Huawei affiliates to the Entity List. The export, reexport, and transfer to these entities of commodities, software, and technology...more

Commerce Department Issues Temporary General License Authorizing Certain Transactions with Huawei and its Designated Affiliates

• On May 20, 2019, the U.S. Department of Commerce published a 90-day Temporary General License (TGL) authorizing limited categories of exports, reexports, or transfers that are otherwise prohibited pursuant to the addition...more

Commerce Adds Huawei, Its Non-US Affiliates Worldwide and Others to the Entity List

• On May 16, 2019, the U.S. Department of Commerce published a final rule adding Huawei and 68 other companies, mostly its non-U.S. affiliates worldwide, to the Entity List... The rule will be officially published in the...more

President Trump Declares National Emergency to Secure the Information and Communications Technology and Services Supply Chain

• On May 15, 2019, President Trump issued a long-awaited E.O. designed to curtail the use of telecommunications items and services from certain countries and persons in U.S. networks. The E.O. does not impose immediate...more

Cleared for Takeoff: OFAC’s General License J Allows Boeing, Airbus and Other Aircraft to Land in Iran

On July 29, 2016, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued a new General License J (GL-J). GL-J authorizes the reexportation of certain civil aircraft on temporary sojourn to Iran,...more

What Implementation of the Iran Nuclear Deal Means for Non-U.S. Companies

On January 16, 2016, the International Atomic Energy Agency (IAEA) verified, and U.S. Secretary of State John Kerry confirmed, that Iran had implemented its key nuclear-related measures described in the Joint Comprehensive...more

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