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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

Commerce Launches Rulemaking Process on Foundational Technologies, Hints at Three Potential Areas of Control

BIS will be looking at items that are controlled only for anti-terrorism, crime control, short supply, United Nations embargoes, or designated as EAR99 in establishing new Foundational Technologies Controls. Two years...more

BIS Expands the Huawei Foreign Direct Product Rule to Capture a Wide Swath of COTS Products

On August 17, 2020, the Department of Commerce, Bureau of Industry and Security (BIS) issued a final rule (the Final Rule) (1) adding additional Huawei non-US affiliates to the Entity List, (2) confirming the expiration of...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

US Government Hurls Another Export Control Grenade at Huawei

On Friday, May 15, 2020, the Department of Commerce and the Bureau of Industry and Security (BIS) revised an arcane export control rule that imposes US export controls on foreign-origin products (hardware, software, and...more

Reference Guide: Worldwide Export Controls on Face Masks and Other Medical Personal Protective Equipment (Updated May 11, 2020)

As the COVID-19 pandemic has expanded exponentially, so too has the demand by hospitals and other healthcare providers for masks and other medical personal protective equipment (PPE) to protect doctors, nurses, and other...more

RIP CIV! BIS to Remove License Exception CIV from the EAR

Rumors have circulated through the export community for months, and the Bureau of Industry and Security (BIS) has finally acted. In a final rule published April 28, 2020, BIS is removing License Exception Civil End-Users...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

APR in APRIL, BIS MAY Make Changes to Restrict Re-Exports, Comments Due in JUNE

On April 28, the Bureau of Industry and Security (BIS) issued a proposed rule that would revise License Exception Additional Permissive Re-Exports (APR) to remove a current provision that allows for reexports of items subject...more

Reference Guide: Worldwide Export Controls on Face Masks and Other Medical Personal Protective Equipment (Updated)

As the COVID-19 pandemic has expanded exponentially, so too has the demand by hospitals and other healthcare providers for masks and other medical personal protective equipment (PPE) to protect doctors, nurses, and other...more

FEMA: Certain Exports of Respirators, Masks, and Gloves (PPE) Exempt From Ban

The Federal Emergency Management Agency has left many important questions blowing in the wind as a result of a Notification of Exemptions action published for public inspection on Friday, April 17, 2020. The final action will...more

Reference Guide: Worldwide Export Controls on Face Masks and Other Medical Personal Protective Equipment (Updated)

As the COVID-19 pandemic has expanded exponentially, so too has the demand by hospitals and other healthcare providers for masks and other medical personal protective equipment (PPE) to protect doctors, nurses, and other...more

FEMA Temporarily Halts Exports of Certain PPE

The Federal Emergency Management Agency (FEMA) has exercised its delegated authority under the Defense Production Act (DPA) to issue a temporary final rule (Prioritization and Allocation of Certain Scarce or Threatened Health...more

Reference Guide: Worldwide Export Controls on Face Masks and Other Medical Personal Protective Equipment

As the COVID-19 pandemic has expanded exponentially, so too has the demand by hospitals and other healthcare providers for masks and other medical personal protective equipment (PPE) to protect doctors, nurses, and other...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

Second Shoe Drops on US Chem-Bio Sanctions on Russia: Did Anyone Hear It?

On Friday, August 2, 2019, the US State Department announced the issuance of another round of sanctions on the Russian Government in relation to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991...more

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