On Friday, March 18, 2022, in response to the continued escalation in Ukraine, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) identified both private and commercial aircraft that have flown to Russia...more
In addition to compliance considerations under US sanctions associated with activities of U.S. persons, companies should also ensure that their compliance programs take into account the expansion under U.S. export controls of...more
12/13/2021
/ Burma ,
Cambodia ,
Chemical Weapons ,
Chief Compliance Officers ,
China ,
Compliance ,
Defense Sector ,
Export Administration Regulations (EAR) ,
Export Controls ,
Military End Use ,
National Security ,
Nuclear Weapons ,
Prohibited Transactions ,
Russia ,
U.S. Commerce Department ,
Venezuela
U.S. and multinational companies with business involving China should be on the alert given recent changes in U.S. export controls and sanctions. During the months of June and July this year, the U.S. government has taken...more
9/2/2021
/ Biden Administration ,
China ,
Compliance ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Hong Kong ,
Multinationals ,
National Security ,
SDN List ,
Supply Chain ,
Trump Administration
Adding to the challenges of implementing the expanded military end use/end user rule in Part 744.21 of the Export Administration Regulations (“EAR”), restrictions on transactions involving military-intelligence end uses and...more
As 2020 comes to a close, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) continues to implement new measures targeting countries of interest, among them Russia and China (which now, for export...more
12/30/2020
/ Bureau of Industry and Security (BIS) ,
China ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Final Rules ,
General Licenses ,
Hong Kong ,
Military End Use ,
National Security ,
U.S. Commerce Department
In addition to the many changes targeted specifically at national security concerns related to China, Russia, and Venezuela, the Bureau of Industry and Security (“BIS”) has implemented a number of additional regulatory...more
11/9/2020
/ Bureau of Industry and Security (BIS) ,
Censorship ,
China ,
Compliance ,
Excessive Force ,
Export Controls ,
Exports ,
Final Rules ,
Hong Kong ,
Human Rights ,
Licensing Rules ,
National Security
While the pandemic has slowed down many things this year, it did not impede progress by the Department of Commerce’s Bureau of Industry and Security (“BIS”) in publishing various regulatory changes aimed at addressing...more
11/4/2020
/ Amended Regulation ,
Bureau of Industry and Security (BIS) ,
China ,
Compliance ,
Department of Defense (DOD) ,
Export Administration Regulations (EAR) ,
Foreign Direct Product Rule ,
Licensing Rules ,
Military End Use ,
National Security ,
Russia ,
Venezuela
In a burst of activity, the US Department of Commerce, Bureau of Industry and Security (BIS) issued two final rules and one proposed rule. These rules, published in the Federal Register on April 28, 2020, made a series of...more
5/1/2020
/ Bureau of Industry and Security (BIS) ,
China ,
Defense Sector ,
ECCNs ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Final Rules ,
General Licenses ,
National Security ,
Proposed Regulation ,
Russia ,
U.S. Commerce Department ,
Venezuela
As we discussed in our last alert, Congress has exhibited increased willingness to consider imposing sanctions in order to advance US foreign policy interests. Multiple sanctions-related bills are currently under...more
On December 13, 2019, the US Department of Justice (DOJ) issued an update to its 2016 guidance regarding enforcement in export control and sanctions investigations of businesses. The updated policy now offers voluntary...more
12/20/2019
/ Compliance ,
Cooperation ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
Financial Institutions ,
Government Investigations ,
Guidance Update ,
National Security ,
Remediation ,
Terrorism Funding ,
Voluntary Disclosure
The Trump Administration announced last week that the US Government has added Huawei to the Commerce Department Entity List and, as of May 20, 2019, has announced a temporary general license for certain transactions. Here is...more
5/22/2019
/ China ,
Economic Sanctions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Huawei ,
Licensing Rules ,
National Security ,
Supply Chain ,
Telecommunications ,
Trump Administration ,
U.S. Commerce Department