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As the (Customs and Trade) World Turns: September 2024

Welcome to the September 2024 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

As the (Customs and Trade) World Turns: August 2024

Welcome to the August 2024 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

Does the Proposed New ITAR Definition of ‘Defense Services’ Catch More Than it Releases in the Foreign Intelligence Area?

On July 29, the Directorate of Defense Trade Controls (DDTC) of the US Department of State proposed a new definition of the term “defense service.” The International Traffic in Arms Regulations (ITAR) imposes a license...more

Footnote Frenzy: Charting Out Commerce’s Proposed Expanded US Person and End Use Export Controls and Facial Recognition Controls

On July 29, the US government proposed big changes to rules about supporting or exporting to foreign military, intelligence, and security entities. The US Department of Commerce’s Bureau of Industry and Security (BIS) is...more

As the (Customs and Trade) World Turns: June 2024

Welcome to the June 2024 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

US Government Throws “Kitchen Sink” Export Controls at Russia, Plus Sweeping EAR99 Software Controls, and IT and Software Services...

Three US agencies – the US Department of Commerce, Bureau of Industry and Security (BIS), the US Department of the Treasury, Office of Foreign Assets Control (OFAC), and the US Department of State – took new actions on June...more

As the (Customs and Trade) World Turns: May 2024

Welcome to the May 2024 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

CFIUS Bites Back: Proposed New Enforcement Powers and Penalties

In an effort to give the Committee on Foreign Investment in the United States (CFIUS) more “bite,” yesterday the Committee published a Notice of Proposed Rulemaking (NRPM) in the Federal Register to enhance its procedures and...more

US Sanctions Hundreds More on Second Anniversary of Russia’s Invasion, Highlights Perils of Continuing Business in Russia, But...

Two years after the start of Russia’s war in Ukraine and one week after the death of opposition politician and anticorruption activist Aleksey Navalny, the US government announced a new raft of sanctions and export controls...more

Commerce Tidies Up the Russia/Belarus Export Controls and Adds Aircraft and Drones (HTS Ch 88) to Its License Requirements

On January 25, almost two years after Russia’s further invasion of Ukraine, the US Department of Commerce, Bureau of Industry and Security (BIS) issued a final rule (the Rule) strengthening existing export controls relating...more

NOT Letting The Chips Fall Where They May: Top 10 Ways the US Has Beefed Up Export Controls on Chinese Chips and Semiconductor...

Just in case you were starting to get comfortable with last year’s massive raft of regulations on the advanced computing, supercomputer, and semiconductor industries in China, the US Department of Commerce, Bureau of Industry...more

Stopping Just Short of the Kitchen Sink, USG Requires Licenses for Exports of Entire HTS Chapters to Russia

During the G7 meeting in Japan on May 19, 2023, the US Department of Commerce’s Bureau of Industry and Security (BIS) published two new rules aimed at further restricting Russia’s ability to obtain items needed to support its...more

More Stick Than Carrot for “Significant” Export Violations from the Bureau of Industry & Security Office of Export Enforcement

Voluntary No More - In taking steps to take the “voluntary” out of voluntary disclosure, Assistant Secretary of US Export Enforcement Matthew Axelrod issued another memorandum on April 18, 2023, following on his June 2022...more

What You Need to Know about the New Russia/Belarus Sanctions, Export Controls, Tariffs & Duties

On Friday, February 24, the one-year anniversary of Russia’s further invasion into Ukraine, President Biden, the Office of Foreign Assets Control (OFAC), the US Department of State, and the US Department of Commerce, Bureau...more

US Drops New Export Controls on the Chinese Semiconductor, Advanced Computing, and Supercomputer Industries

On Friday, October 7, 2022, the Bureau of Industry and Security (BIS) released an interim final rule containing an enormous set of export controls that will likely damage the Chinese semiconductor, advanced computing, and...more

Summer Vacation’s Over: Commerce Imposes New Russia and Belarus Export Controls

Well, the Bureau of Industry and Security (BIS) waited until the summer was over, but timing may be the best part of the new export controls on Russia and Belarus (the “Rule”). Understanding the new Rule and how the old...more

Two New ITAR Open General Licenses: Five Stars for Effort but Can We Really Use Them for Anything Other than Repair and...

In an exciting turn of events in the world of the International Traffic in Arms Regulations (ITAR), the US Department of State, Directorate of Defense Trade Controls issued two open general licenses (OGLs) authorizing the...more

CBP Releases Uyghur Forced Labor Prevention Act (UFLPA) Operational Guidance

US Customs and Border Protection (CBP) UFLPA Operational Guidance for Importers (CBP Guidance) was published on June 13, 2022 to assist importers in preparing for the UFLPA rebuttable presumption that goes into effect on June...more

Mother’s Day Sanctions: United States Bans Accounting, Management & Other Services to Russia, Demands More Export Licenses

On May 8, 2022 (aka Mother’s Day), the Biden Administration announced yet another series of export controls and sanctions measures intended to ratchet up the costs on Russia’s economy and limit its ability to continue its war...more

US Blocks More Russian Elites, Imposes Import Restrictions on Energy & More, Adds Export Controls on Luxury Goods

Watch Out, More Things Are Luxury Than You Think! On March 11, 2022, the President issued Executive Order 14068 (EO 14068) Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian...more

US Sanctions Belarus and Piles on More Russian Sanctions: What You Need to Know

In a coordinated effort, on March 2, 2022, the White House announced another round of broad trade controls and sanctions against Russia and now Belarus in response to Russia’s military invasion of Ukraine. The White House...more

OFAC Latest Steps: Blocking Putin and Senior Officers, Further Targeting Sovereign Russian Financial Entities, and Publishing...

On February 25 and 28, 2022, the US Treasury Department, Office of Foreign Assets Control (OFAC) issued its fifth and sixth actions against Russia, blocking the assets of President Vladimir Putin and three other high-ranking...more

Unprecedented Broad Export Controls and Sanctions on Russia Go into Effect – (Some) Immediately!

What Are the New US Export Controls on Russia? On February 24, 2022, the US Department of Commerce, Bureau of Industry and Security (BIS) imposed new export controls intended to restrict access to technologies and other...more

Importers Should Prepare for More Forced Labor Detentions

CBP Adds Second Forced Labor Investigations Branch and DHS Publishes Timeline for Actions - Importers should be prepared for increased forced labor actions (including new Withhold Release Orders and product import bans)...more

Commerce Department Signals Tough Approach on China Under Controversial Trump Tech Supply Chain EO

The subpoena issuance suggests that the Biden Administration will continue the US Government’s assertive approach to China. The US Department of Commerce, on March 17, 2021, issued subpoenas on multiple Chinese companies...more

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