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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

US Moves to Treat Hong Kong Like China: What Does This Mean for US Exporters?

On Monday, June 29, the Departments of Commerce and State announced that they were following through with changes to treat Hong Kong like China for exports of military and dual-use goods. The Department of Commerce announced...more

Ahoy, Exporters to China, Russia, and Venezuela! Massive Military End Use/User Controls & Reporting Icebergs Lie Ahead!

In yet another action on April 28, 2020, the Bureau of Industry and Security (BIS) issued a final rule imposing stricter license requirements on a wide range of exports, reexports and transfers to China, Russia, or Venezuela...more

ITAR Defense Controls Catches Up to Modern IT, Allowing Exporters to Use Encryption to Protect Defense Technology on the Cloud

The good news is that, for the most part, State resisted the temptation to do something just a little different in the ITAR regulation, so the joint Commerce-State solution works. The chart below provides a quick side-by-side...more

BIS Imposes Additional Cuba Trade Restrictions and Restricts Use of Temporary Sojourn License Exception for Multiple Countries

BIS has restricted Cuba’s access to commercial aircraft and other goods, lowered de minimis for foreign items containing US content to 10%, and restricted the temporary sojourn by aircraft in Iran, Syria, Sudan, and North...more

US State Department Seeks Feedback on Amorphous Human Rights Due Diligence for US Exporters of ‘Surveillance’ Items

The US State Department is soliciting feedback on its draft “US Government Guidance for the Export of Hardware, Software, and Technology with Surveillance Capabilities and/or Parts/Know-How,” issued September 4, 2019 (Draft...more

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