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BIS Imposes New Export Controls on Quantum, Semiconductor and Additive Manufacturing Technologies

On September 5, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule imposing significant new export controls on quantum computing, cryocooling systems, semiconductor...more

State Department Proposes Exempting Australia, UK from Certain Defense Related Export Controls

On April 30, 2024, the Department of State proposed an amendment to the International Traffic in Arms Regulations (ITAR) intended to facilitate exports of defense articles, the performance of defense services, and brokering...more

Correcting and Clarifying Export Controls Issued on Advanced Computing and Semiconductor Manufacturing Items

On March 29, 2024, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) issued an interim final rule (“2024 IFR”) clarifying and correcting its October 2023 interim final rules on advanced...more

China Year-in-Review: Securing the Battery Supply Chain

During 2023 both Congress and the Biden Administration repeatedly expressed the need to secure critical supply chains, particularly batteries that rely heavily on lithium and critical minerals sourced from China. Concerns...more

Unveiling the New European Economic Security Strategy

The EU’s new Joint Communication on a European Economic Security Strategy proposes a methodology for an EU economic security risk assessment and identifies measures to mitigate these risks. The Strategy is noteworthy because...more

Russia Sanctions Year in Review: Impact on Aviation Sector

This post marks the third entry in our Year-in-Review series. For prior posts, click here. Many of the first measures that the United States, European Union and United Kingdom collectively took against Russia in 2022 related...more

Navigating Russia Sanctions: Strategies for Companies to Mitigate Supply Chain Risks

In response to Russia’s invasion of Ukraine, and Belarus’s role in enabling this attack, the United States and global allies have imposed sweeping sanctions and export control restrictions on both Russia and Belarus. These...more

State Department Issues Two Open General Licenses Authorizing Reexports and Retransfers of Certain Defense Articles for Australia,...

On July 13, 2022, as part of a new pilot program, the Department of State’s Directorate of Defense Trade Controls (“DDTC”) issued two open general licenses (“OGLs”) permitting certain reexports and retransfers of unclassified...more

BIS Hits Russia and Belarus with Sweeping New Export Control Restrictions

On February 24, 2022, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued a final rule effective immediately imposing sweeping export control restrictions against Russia in response to Russia’s...more

Further EU and UK Measures Taken Against Russia

As the Russian invasion of Ukraine continues, the global pressure on the Putin regime intensifies with the EU issuing additional sanctions and export controls on Friday evening (February 25). The legislation implementing the...more

Commerce Imposes New Export Controls on Cybersecurity Items and Adds a Corresponding License Exception

On October 21, 2021, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) announced an interim final rule (Interim Rule), which will amend the Export Administration Regulations (EAR) to add controls for the...more

U.S. Commerce Department Publishes Lists of Military End Users in China and Russia Subject to Export License Requirements

On December 21, the Bureau of Industry and Security (BIS) published a Military End User (MEU) list to further implement the military end user/end use (MEU) rule defined in Section 744.21 of the Export Administration...more

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

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

BIS Amends Direct Product Rule To Target Huawei But Extends Huawei Temporary General License

On May 15, 2020 the Commerce Department announced an amendment to the direct product rule that further restricts the ability of Huawei Technologies Co., Ltd. and its affiliates on the Entity List, such as HiSilicon...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

Temporary FEMA Rule: Export Approvals Required for Certain Personal Protective Equipment

On April 7, 2020, the Federal Emergency Management Agency (FEMA) released for public inspection a temporary rule that prohibits the export of five types of personal protective equipment (PPE) without explicit approval by...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

Huawei Remains on the BIS Entity List but Senior Officials Suggest Export Licenses May Be Considered

As trade relations with China continue to evolve, Huawei Technologies Co., Ltd. (“Huawei”) and its foreign affiliates remain subject to broad U.S. export license requirements. ...more

Temporary General License Grants Huawei Limited Relief from Restrictions Imposed by Entity List Restrictions

On May 16, 2019, the Bureau of Industry and Security (BIS) of the U.S. Department of Commerce added Huawei Technologies Co., Ltd. (Huawei) and sixty-eight of its non-U.S. affiliates to the Entity List, thereby prohibiting the...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

State Department Imposes Chemical Weapons Sanctions on Russia

On August 8, 2018, the State Department announced that it had concluded that Russia was responsible for poisoning former double agent Sergei Skripal and his daughter Yulia using the nerve agent Novichok and that it had sent a...more

New Proposed Trade Legislation Contains Additional Trade and Investment Restrictions Involving China

There are several legislative proposals pending in Congress targeting trade and investment involving China. If enacted, the proposals would prevent Chinese entities from acquiring certain U.S. technologies, prohibit U.S....more

U.S. Employs Rarely Used Tool to Probe China IP Practices

As President Trump visits China, U.S. is investigating a longstanding issue in bilateral relationship—technology transfer/intellectual property requirements—that has potential implications for trade. U.S. business and...more

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