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
Funding provided under the Infrastructure Investment and Jobs Act (IIJA) is conditioned on complying with domestic content requirements.
The Office of Management and Budget (OMB) has proposed new regulations to implement...more
This post marks the second entry in our Year-in-Review series. For prior posts, click here. Few sectors have been more affected by the sanctions on Russia than the energy industry....more
On February 24, 2022, the United States (U.S.), European Union (EU), United Kingdom (UK), and other countries issued a barrage of sanctions against the Russian financial sector, cutting off many major banks from the global...more
On December 5, 2022, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $60 per barrel price cap on maritime transfers of Russian-origin crude oil. The final cap level is being implemented...more
Various reports indicate that the Group of Seven nations (G7) will announce its initial capped price for Russian-origin crude oil transported by maritime means (“seaborne”) this week. The cap will come into effect on December...more
On October 28, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued guidance on its October 7, 2022 interim final rule (Rule) that imposed new export controls on certain advanced computing...more
On October 7, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule (the “Rule”) imposing sweeping new export controls targeting certain advanced computing integrated...more
In the final few days of September, the U.S. and global allies issued a number of sanctions and export controls against actors who have supported Russia’s referendums in Ukraine and related attempts to annex four Ukrainian...more
Takeaways - The G7 has announced consensus on a price cap for Russian origin oil and petroleum products to be implemented across a wide coalition of countries....more
On August 15, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule introducing new controls on four “emerging and foundational technologies” that were identified during the...more
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
Key Takeaways: The Uyghur Forced Labor Prevention Act (UFLPA) went into effect on June 21, 2022, and requires the U.S. Customs and Border Protection (CBP) to presume that all goods manufactured wholly or in part in the XUAR,...more
On May 8, 2022, the White House announced a number of new measures in response to Russia’s ongoing war in Ukraine. The new measures include prohibitions on new categories of services to Russia by U.S. persons; export controls...more
In the last month, the United States and global allies have issued unprecedented sanctions against Russia in response to the war in Ukraine. These sanctions apply ever-expanding pressure on the Russian economy and touch...more
The EU and UK have imposed additional export controls and sanctions with respect to Russia and Belarus connected to the Russian invasion of Ukraine. Below is a summary of key developments over recent days since our last blog...more
3/3/2022
/ Airspace ,
Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Economic Sanctions ,
Export Controls ,
Foreign Relations ,
Proposed Legislation ,
Russia ,
UK ,
Ukraine
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
3/3/2022
/ Belarus ,
Belarus Sanctions ,
Bureau of Industry and Security (BIS) ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
General Licenses ,
Licensing Rules ,
Military End Use ,
Russia ,
U.S. Commerce Department ,
Ukraine
Despite months of posturing and growing geopolitical tensions, Russia’s full-scale invasion of Ukraine this week was a shock to the global community. Western leaders have been swift and unanimous in their response, condemning...more
2/28/2022
/ Anti-Money Laundering ,
Asset Freeze ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
ECCNs ,
Economic Sanctions ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
UK ,
Ukraine
On February 24, 2022, the U.S. Government issued a number of sanctions measures in response to Russia’s attack on Ukraine. These measures include sweeping financial sanctions and stringent export controls, which will have...more
2/25/2022
/ Biden Administration ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Embargo ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
U.S. Treasury ,
Ukraine
Will 2022 Be the Year of Supply Chain Ethics?
Effective June 21, 2022, in an effort to address forced labor concerns, U.S. law will broadly prohibit imports of products from China’s Xinjiang Uyghur Autonomous Region...more
1/19/2022
/ China ,
Compliance ,
Customs and Border Protection ,
Due Diligence ,
Enforcement ,
Environmental Social & Governance (ESG) ,
Ethics ,
Forced Labor ,
Human Rights ,
Imports ,
Sanctions ,
Supply Chain ,
Tariff Act of 1930 ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Withhold Release Orders (WROs)
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
On August 9, 2021, the one-year anniversary of the claimed reelection of Belarusian leader Aleksandr Lukashenka, President Biden issued an “Executive Order on Blocking Property of Additional Persons Contributing to the...more
On July 30, 2021, the Biden Administration published a Proposed Amendment to the Federal Acquisition Regulation (FAR) (Proposed Rule) that, among other things, would impose significantly increased U.S. content requirements...more
The Biden Administration has signaled an expanded commitment to longstanding U.S. anti-corruption policies, and recent enforcement actions and policy announcements provide insights into what foreign officials, companies and...more
U.S. officials have continued to use a range of policy tools to apply pressure on the military leadership of Myanmar (also known as Burma) in response to the military coup in the country and escalating violence against...more