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New U.S. Sanctions Target Turkey’s Defense Sector

On December 14, 2020, the U.S. Department of State initiated a series of sanctions pursuant to Section 231 of the Countering America’s Adversaries Through Sanctions Act (CAATSA) that target the Turkish Presidency of Defense...more

U.S. Commerce Department Implements Multilateral Controls on Six Emerging Technologies

On October 5, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule that imposes new multilateral controls on six “emerging technologies,” agreed during the December 2019 plenary meeting...more

U.S. Commerce Department Announces Prohibited Transactions Related to WeChat and TikTok But Implementation Is Delayed

On September 18, 2020, the U.S. Commerce Department published two rules defining the scope of prohibited transactions related to the mobile applications, WeChat and TikTok. The scope of prohibited transactions clarified the...more

CFIUS Issues Final Rule Basing Mandatory Declaration Requirement on U.S. Export Control Criteria

On September 15, 2020, the U.S. Department of Treasury published a final rule that removes the mandatory declaration requirement for filings to the Committee on Foreign Investment in the United States (CFIUS) based on North...more

BIS Adds 33 Chinese Entities to Entity List

On May 22, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced that it will add 33 Chinese companies and institutions to the Entity List. The designations will prohibit the export,...more

CFIUS Proposes Mandatory Declaration Requirement Based on U.S. Export Control Criteria

On May 21, 2020, the U.S. Department of the Treasury published a proposed rule that would revise the mandatory declaration requirement for foreign investments involving a U.S. business that produces, designs, tests,...more

New Export Control Rules Confront Integration of Civilian and Military Technology Development in China, Russia, and Venezuela

On April 28, 2020, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) published two final rules that will eliminate the license exception for civil end users (CIV) in the People’s Republic of China, Russia,...more

Compliance in 2020 – Key Takeaways from the ITAR Cloud Rule

On December 26, 2019, the Department of State published in the Federal Register an interim final rule amending the International Traffic in Arms Regulations (ITAR) to define “activities that are not exports, reexports,...more

Update on U.S. Government Review of “Emerging and Foundational” Technologies

Recent comments from Bureau of Industry (“BIS”) officials at the BIS Update indicate the U.S. Government is progressing towards more detailed proposed rules with respect to both “emerging” and “foundational” technologies that...more

U.S. Commerce Department Releases Proposed Rulemaking for Export Controls on Emerging Technologies

On November 19, 2018, the US Commerce Department’s Bureau of Industry and Security (BIS) issued a proposed rulemaking seeking public comment on criteria for identifying emerging technologies that are essential to U.S....more

Congress Reaches Agreement on CFIUS Reform Legislation Broadening National Security Reviews and Addressing Emerging Technologies

House and Senate negotiators have agreed on proposed reforms to the Committee on Foreign Investment in the United States (CFIUS) foreign investment review process, which has been added as Title XVII of the FY2019 National...more

President Trump Announces Policy Changes Towards Cuba

On June 16, 2017, President Trump issued a National Security Presidential Memorandum on Strengthening the Policy of the United States Toward Cuba, which begins a process to alter some aspects of U.S. policy towards Cuba, but...more

U.S.-India Defense Cooperation Taken to the Next Level with Favorable Licensing Policy for Exports to India

On January 27, 2017, the Commerce Department’s Bureau of Industry and Security (BIS) recently made two significant changes to the Export Administration Regulations (EAR) concerning India that will facilitate the export of...more

International Trade in the Trump Era — Issues to Watch

Donald Trump’s victory in the 2016 Presidential election put the Republican Party in charge of the White House and Congress for the first time in a decade. President-elect Trump ran as an anti-establishment candidate who...more

Redefining U.S. Export Controls: Takeaways from Key Changes Effective September 1st

On September 1, 2016 new rules previously published by the U.S. Department of Commerce, Bureau of Industry and Security (BIS) and the U.S. Department of State, Directorate of Defense Trade Controls (DDTC) will become...more

Redefining U.S. Export Controls: Takeaways from Key Changes Effective September 1st

On September 1, 2016 new rules previously published by the U.S. Department of Commerce, Bureau of Industry and Security (BIS)1 and the U.S. Department of State, Directorate of Defense Trade Controls (DDTC)2 will become...more

Additional Steps to Ease U.S. Sanctions and Export Controls for Cuba prior to Obama Visit

In advance of President Obama’s highly publicized trip to Cuba, the Administration took additional steps to ease restrictions on trade and travel with Cuba. These changes to the Cuban Assets Control Regulations (CACR) and...more

What about Canada and Australia? Iran Sanctions changes beyond the U.S. and EU

There has been much discussion of U.S. and EU sanctions changes following Implementation Day under the Joint Comprehensive Plan of Action (“JCPOA”), but a number of countries had imposed sanctions for Iran and it is worth...more

A New U.S. Course for Cuba Relations: What Does It Mean for Business?

President Obama made an unexpected announcement this week signaling a “new course” for Cuba after more than fifty years of comprehensive U.S. sanctions. Reestablishing diplomatic relations is a major change. In terms of...more

U.S. and EU Extend Temporary Iran Sanctions Relief a Second Time

The temporary and limited changes to U.S. and European Union (“EU”) sanctions policy for Iran, as agreed under the interim nuclear deal reached by Iran and the P5 + 1 countries, have been extended until June 30, 2015. Most...more

U.S. Steps Up Sanctions and Export Controls Against Russia’s Defense Industry

The United States recently expanded sanctions and export controls against the Russian defense sector. These designations and export control steps have implications for defense contractors, parts suppliers and brokers....more

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