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Just the Facts: 6 Takeaways from BIS’s Semiconductor FAQs

On October 28, 2022, the US Department of Commerce, Bureau of Industry (BIS) issued FAQs on the new semiconductor regulations. The FAQs are short and relatively clear (thank you!) even if they were released on a Friday...more

US Drops New Export Controls on the Chinese Semiconductor, Advanced Computing, and Supercomputer Industries

On Friday, October 7, 2022, the Bureau of Industry and Security (BIS) released an interim final rule containing an enormous set of export controls that will likely damage the Chinese semiconductor, advanced computing, and...more

Summer Vacation’s Over: Commerce Imposes New Russia and Belarus Export Controls

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

Two New ITAR Open General Licenses: Five Stars for Effort but Can We Really Use Them for Anything Other than Repair and...

In an exciting turn of events in the world of the International Traffic in Arms Regulations (ITAR), the US Department of State, Directorate of Defense Trade Controls issued two open general licenses (OGLs) authorizing the...more

US Blocks More Russian Elites, Imposes Import Restrictions on Energy & More, Adds Export Controls on Luxury Goods

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

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

OFAC Latest Steps: Blocking Putin and Senior Officers, Further Targeting Sovereign Russian Financial Entities, and Publishing...

On February 25 and 28, 2022, the US Treasury Department, Office of Foreign Assets Control (OFAC) issued its fifth and sixth actions against Russia, blocking the assets of President Vladimir Putin and three other high-ranking...more

Unprecedented Broad Export Controls and Sanctions on Russia Go into Effect – (Some) Immediately!

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

US Imposes Territorial Sanctions on Ukrainian Breakaway Republics & Broader Russia Based Sanctions: What You Need to Know

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

Uyghur Forced Labor Prevention Act Becomes Law: Importers Must Prepare for Increased Enforcement and Detentions at the Border

US importers should participate in the Task Force's comment and hearing process to flag due diligence challenges and formulate the strategy to enforce the import prohibitions. What to Know - Effective June 21, 2022, 180...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

US Individuals Providing Defense Services Abroad Need a State Department License or Face Potential Prosecution

On September 7, 2021, three former U.S. Intelligence Community and military personnel (Defendants) entered into a Deferred Prosecution Agreement (DPA) with the U.S. Attorney’s Office for the District of Columbia and the U.S....more

CBP Issues WRO on Solar Materials Made By Chinese Companies

Forced Labor Enforcement Continues to Escalate as Commerce Restricts Exports to 5 Additional PRC Companies - Withhold release order was issued that will prohibit imports of products produced in whole or part from silica...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

President Biden Orders 100-Day Review of America’s Supply Chains for Semiconductors, Batteries, Critical Minerals and APIs

Changes are afoot for key industry sectors with complicated global supply chains. “As this pandemic has made clear, we can never again be in a position where we have to rely on a foreign country that doesn’t share our...more

‘Foreign Adversaries’ In Tech Supply Chain May Be Under the Microscope

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

The US Automotive Industry: Global Players Facing Tightened US Trade Rules

The growing role that international trade rules are playing has left many corporate leaders to look beyond regularly imposed tariffs. Earlier this month, we published our “Advance Look at Hot Button Trade Issues under the...more

Navigating Section 889 of the 2019 National Defense Authorization Act  [Audio]

Arent Fox International Trade Group Partner Marwa Hassoun and Government Contracts Group Counsel Travis Mullaney chat about Section 889 of the National Defense Authorization Act. In today's episode, we focus on the U.S....more

UN Relaxes International Control of Cannabis, Signaling Big Changes on the Horizon

Cannabis and cannabis resin, formerly classified on the most restrictive schedule under the 1961 Single Convention on Narcotic Drugs (Single Convention) were moved to the least restrictive schedule following a historic vote...more

Trump Administration Bars Investments by US Persons in Communist Chinese Military Companies

In his last days, President Trump takes a swipe against companies identified by the Department of Defense (DoD) as Communist Chinese military companies by prohibiting US persons from investments. On November 12, 2020,...more

US Expands Military License Review Factors for National Security Controlled Items to PRC, Venezuela, and Russia

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

CFIUS 2.0: Mandatory Filings Now Pegged to Export Control Rules

The Committee on Foreign Investment in the United States (CFIUS) is now following new rules on mandatory filings for certain foreign investments in critical technology companies. As a refresher, CFIUS is the US Government’s...more

Human Rights Now Part of US Export Licensing Review for Nearly All Export Licenses

Target areas are telecom, information security, and sensor items that can be used for censorship, surveillance, detention, and use of force. On October 6, 2020, the US Department of Commerce, Bureau of Industry and...more

OFAC’s New Ransomware Advisory

On October 1, 2020, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an Advisory highlighting sanctions risks associated with facilitating ransomware payments on behalf of victims targeted by...more

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