Key Points -
On January 16, 2024, Matthew Axelrod, Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s BIS announced key updates to BIS’s VSD process. The updates are also now reflected on BIS’s...more
1/26/2024
/ Bureau of Industry and Security (BIS) ,
Enforcement ,
Export Administration Regulations (EAR) ,
Exports ,
National Security ,
Negligence ,
Non-Prosecution Agreements ,
Penalties ,
Penalty Reductions ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
Voluntary Disclosure
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
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
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 U.S. Department of Commerce has published a highly complex and novel interim final rule extending the controls of the Export Administration Regulations (EAR) over foreign-made items in Huawei’s contract manufacturing...more
5/21/2020
/ Bureau of Industry and Security (BIS) ,
Comment Period ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Direct Product Rule ,
Foreign Policy ,
General Licenses ,
Huawei ,
Interim Final Rules (IFR) ,
Manufacturers ,
National Security ,
Prohibited Transactions ,
Public Comment ,
Supply Chain ,
Technology Sector ,
Telecommunications ,
U.S. Commerce Department
- 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
4/30/2020
/ Bureau of Industry and Security (BIS) ,
Exceptions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Final Rules ,
General Licenses ,
Licensing Rules ,
Military End Use ,
National Security ,
Proposed Rules ,
U.S. Commerce Department
- 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
- Recent actions by the U.S. government and NGOs have intensified international focus on labor conditions in China’s Xinjiang Uyghur Autonomous Region (XUAR) and companies that allegedly source materials and labor from the...more
The new coronavirus, SARS-CoV-2, and the disease it causes, COVID-19, have created diverse, complex, and immediate challenges for world governments, multinational businesses, and other international institutions and projects....more
3/10/2020
/ Airports ,
Coronavirus/COVID-19 ,
Economic Sanctions ,
Exports ,
Federal Funding ,
Health and Safety ,
Imports ,
Infectious Diseases ,
Manufacturers ,
Medical Supplies ,
Multinationals ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Public Health ,
Risk Assessment ,
Supply Chain ,
Trade Relations ,
Travel Restrictions ,
Travelers
- 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
2/21/2020
/ Blocked Person ,
Crude Oil ,
Economic Sanctions ,
Energy Sector ,
Export Controls ,
Exports ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Venezuela
• On January 6, 2020, DDTC published a new FAQ on Defense Services Performed by U.S. Persons Abroad, confirming that the ITAR regulate defense services performed by a U.S. person employed by a non-U.S. company outside of the...more
• 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
8/21/2019
/ Bureau of Industry and Security (BIS) ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
General Licenses ,
Huawei ,
Prohibited Transactions ,
Software ,
Technology Sector ,
Telecommunications ,
U.S. Commerce Department
• 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
5/22/2019
/ Bureau of Industry and Security (BIS) ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
General Licenses ,
Huawei ,
Manufacturers ,
National Security ,
Prohibited Transactions ,
Supply Chain ,
Technology Sector ,
Telecommunications ,
U.S. Commerce Department
• 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
5/20/2019
/ Bureau of Industry and Security (BIS) ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Final Rules ,
Foreign Policy ,
General Licenses ,
Huawei ,
National Security ,
Technology Sector ,
U.S. Commerce Department
• As of November 5, 2018, the United States concluded the second of two wind-down periods for re-imposition of U.S. sanctions on Iran following the May 8, 2018, announcement that the United States would cease participation in...more
11/27/2018
/ Aircraft ,
Blocking Statutes ,
Cross-Border Transactions ,
Economic Sanctions ,
EU ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Goods or Services ,
Humanitarian Assistance ,
Imports ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
SDN List ,
Special Purpose Vehicles ,
SWIFT ,
Trade Policy ,
Trump Administration ,
Vessels
• On May 22, 2018, OFAC issued General License 15, authorizing U.S. persons to engage in specified transactions related to maintenance or wind-down of operations, contracts or other agreements involving GAZ Group or any...more
• The U.S. government has withdrawn from the Iran Nuclear Deal and reverted sanctions to the status quo ante by re-imposing secondary sanctions that restrict non-U.S. persons from engaging in a broad range of business in...more
5/10/2018
/ Controlled Foreign Corporations ,
Economic Sanctions ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trade Policy ,
Trump Administration
Today, OFAC issued General License 14, authorizing U.S. persons to engage in specified transactions related to maintenance or wind down of operations, contracts or other agreements involving RUSAL until October 23, 2018,...more
Based on certain State Department findings, effective October 12, 2017, long-standing U.S. sanctions on the Republic of Sudan administered by OFAC under the Sudan Sanctions Regulations will be terminated, and U.S. persons...more
10/13/2017
/ Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Commodities ,
Department of Defense (DOD) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secretary of State ,
Sudan ,
Trade Restrictions ,
Trump Administration ,
TSRA
On September 21, 2017, the White House announced additional sanctions against North Korea, following a new round of sanctions imposed by the United Nations on September 11 and an escalation of U.S. sanctions previously...more
9/26/2017
/ Aircraft ,
Anti-Terrorism Financing ,
Economic Sanctions ,
Executive Orders ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Fund Transfers ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Secretary of State ,
Secretary of the Treasury ,
Trade Restrictions ,
Trump Administration ,
Vessels
On August 2, 2017, President Trump signed into law the Countering America’s Adversaries Through Sanctions Act of 2017 (Pub. Law. No. 115-44, H.R. 3364) (the “Act”), which significantly expands economic sanctions against...more
8/9/2017
/ Anti-Corruption ,
Anti-Terrorism Financing ,
Arms Embargo ,
Congressional Override ,
Cyber Sanctions ,
Economic Sanctions ,
Executive Orders ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
North Korea ,
Oil & Gas ,
Pipelines ,
Privatization ,
Russia ,
SDN List ,
SSI List ,
State-Owned Enterprises ,
Syria ,
Trade Restrictions ,
Trump Administration
On December 23, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a Final Rule amending the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR) to expand the...more