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U.S. proposes revisions to “defense service” definition and related export controls

On July 29, 2024, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) issued a proposed rule to revise the definition of “defense service” and the scope of related controls under existing International...more

BIS and DDTC take steps to update U.S. export controls to support AUKUS

In mid-April, the U.S. Departments of Commerce and State took a series of related actions to support implementation of the Australia, UK, and U.S. Trilateral Security Partnership. On April 19, 2024, BIS issued an Interim...more

U.S. Department of Justice updates its Enforcement Policy for Business Organizations

On March 7, 2024, the U.S. Department of Justice’s National Security Division (NSD) issued an updated Enforcement Policy for Business Organizations. The updated policy encourages companies to voluntarily disclose to NSD...more

Biden Administration investigates national security risks of Chinese connected vehicles in the U.S.

On Feb. 29, 2024, the White House announced that the Commerce Department’s Bureau of Industry and Security would issue an advance notice of proposed rulemaking as part of the Biden Administration’s investigation of national...more

BIS further enhances voluntary self disclosure process for minor or technical violations

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has further updated its voluntary self-disclosure (VSD) process by establishing streamlined procedures for minor or technical violations of the Export...more

US intensifies export control restrictions on semiconductor and supercomputing activities

The Department of Commerce’s Bureau of Industry and Security issued two interim final rules to expand on the 7 October 2022 restrictions aimed at denying access to certain advanced semiconductors, semiconductor manufacturing...more

DOJ announces policy for self-disclosures on criminal misconduct of acquired companies, with a catch

Deputy Attorney General Lisa Monaco announces a new safe harbor policy for voluntary self-disclosures of acquired entities’ criminal misconduct. Although the new safe harbor provides clear timelines for disclosure, the costs...more

Legislation to grant U.S. government sweeping authority over ICT-related national security threats

On 7 March 2023, U.S. Senators Mark Warner and John Thune introduced the Restricting the Emergence of Security Threats that Risk Information and Communications Technology (RESTRICT) Act, sweeping legislation aimed at...more

Aerospace & Defense Insights | DDTC outlines expectations for global compliance

Through Aerospace & Defense Insights, we share with you the top legal and political issues affecting the aerospace and defense (A&D) industry. Our A&D industry team monitors the latest developments to help our clients stay in...more

U.S. implements new export controls on toxins, plant pathogens and biological equipment

The United States Department of Commerce’s Bureau of Industry and Security has issued regulations to amend the Export Administration Regulations to implement changes to controls of certain viruses, marine toxins, plant...more

BIS imposes significant new export controls on China regarding semiconductors and supercomputers

The Department of Commerce’s Bureau of Industry and Security has issued an interim final rule to deny China’s access to certain semiconductor and advanced computing technology and to inhibit China’s ability to manufacture...more

OFAC issues guidance on implementation of G7 price cap on Russian crude oil and petroleum products

On 9 September 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published “Preliminary Guidance on Implementation of a Maritime Services Policy and Related Price Exception for Seaborne...more

BIS continues to expand export controls on Russia and Belarus and adds 71 entities to the Entity List

On 2 June 2022, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) issued two final rules, effective on the same day, that revised the Export Administration Regulations (“EAR”) pertaining to the U.S.’s...more

OFAC Authorizes Transactions in Listed Sectors in Connection with Non-Regime Held Areas of Syria

The Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) No. 22 on May 12, 2022, authorizing transactions that are ordinarily incident and necessary to activities that occur in specified, non-regime held...more

Summary of February 24 U.S. sanctions and export controls on Russia

On February 24, 2022, the US Government imposed severe economic sanctions and export controls on Russia. The restrictions consist of two parts: 1) significant financial sanctions on a range of Russian financial institutions...more

Aerospace and Defense Insights | SPAC transactions update: Are space and satellite companies still good candidates?

Since late 2019, space- and satellite-based companies and other companies in the aerospace and defense sector have been the focus of interest from special purpose acquisition companies (SPACs). Similarly, SPACs have been...more

Ransomware sanctions and the U.S. Government's latest strategy to address cyber threats

The decision to pay millions to a cyber criminal has never been easy, but it is now even more complex. The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory on September 21,...more

Aerospace & Defense Insights | Special purpose acquisition company (SPAC) transactions: Are space and satellite companies good...

Since late 2019, space- and satellite-based companies and other companies in the aerospace and defense sector have been the focus of interest from special purpose acquisition companies (SPACs). Similarly, SPACs have been...more

Cuban Assets Control Regulations amendments further restrict travel and trade

The Cuban Assets Control Regulations have been amended to prohibit U.S. persons from lodging at certain properties in Cuba, incorporate restrictions on imports of Cuban alcohol and tobacco, and revoke general licenses...more

President issues executive order eliminating Hong Kong's preferential treatment

On 14 July, the same day the president signed into law the Hong Kong Autonomy Act (the act), President Trump issued the Executive Order on Hong Kong Normalization (the EO) directing federal agencies to impose a range of trade...more

BIS issues frequently asked questions to clarify the military end use/user rule

On 29 June 2020, the final rule expanding the military end user/user controls (MEU) issued by the Bureau of Industry and Security (BIS) went into effect. On 26 June 2020, BIS issued an FAQs guidance document that provides...more

Department of Defense Lists Chinese Companies, with Chinese Military Ties, Operating in the United States

On 24 June 2020, the United States Department of Defense made public a list of Chinese companies operating in the U.S. that are associated with the Chinese military. ...more

China Entity List designations

On Friday, May 22, 2020, the US Department of Commerce, Bureau of Industry and Security (BIS) announced in two separate press releases that it would be adding a number of companies and governmental entities to the Entity...more

U.S. decertification under the Hong Kong Policy Act – what is changing now, and what happens next?

On 27 May 2020 U.S. Secretary of State Pompeo certified to Congress that the State Department no longer considers Hong Kong to have significant autonomy from China and therefore "Hong Kong does not continue to warrant...more

BIS Expands Foreign-Produced Direct Product Rule With Regard to Huawei

The Commerce Department’s Bureau of Industry and Security has announced an Interim Final Rule amending the Export Administration Regulation’s General Prohibition Three, the foreign-produced direct product rule....more

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