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Commerce Initiates Rulemaking Targeting Foreign-Manufactured Technology Used In Connected Vehicles

On Thursday, February 29th, 2024, the Department of Commerce (“the Department”) announced an advance notice of proposed rulemaking (“ANPRM”), seeking public comments regarding new potential regulations to ​“secure and...more

Commerce Proposes KYC and Other Cybersecurity Requirements on Cloud Services and AI Training

On January 29, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) published a notice of proposed rulemaking (NPRM) introducing a Customer Identification Program (CIP) and other requirements applicable to...more

BIS Proposes KYC and Other Cybersecurity Requirements on Cloud Services and AI Training

On January 29, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) published a notice of proposed rulemaking (NPRM) introducing a Customer Identification Program (CIP) and other requirements applicable to...more

BIS Hits Wabtec Corporation with $153,175 Civil Penalty for Antiboycott Violations

On January 29, 2024, the Commerce Department’s Bureau of Industry and Security (“BIS”) announced a settlement with Wabtec Corporation of $153,175 for violations of the antiboycott provisions of the Export Administration...more

Commerce Department Expands Russia and Belarus Controls, Implements Clarifying Changes

On January 25, 2024, the Commerce Department’s Bureau of Industry and Security (“BIS”) strengthened its existing controls under the Export Administration Regulations (“EAR”) against Russia and Belarus. Specifically, BIS is...more

BIS Clarifies Notification and Licensing Requirements for Updated Semiconductor, Advanced Computing Export Controls

On December 29, 2023, the Commerce Department’s Bureau of Industry and Security (BIS) issued Frequently Asked Questions (FAQs) concerning the agency’s recently updated semiconductor and advanced computing export controls. In...more

White House Broadens Restrictions on Russia by Authorizing Sanctions on Foreign Financial Institutions and Expanding the Import...

On December 22, 2023, President Biden signed Executive Order 14114, titled ​“Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities” (EO 14114), with a focus on holding foreign financial...more

House 90-Day Review Report Calls for “Win-At-All-Costs” Approach to Preventing PRC Access to Critical U.S. Technology

On December 7, 2023, the U.S. House of Representative’s Foreign Affairs Committee (House Committee) released a 90-day report (the Report) on the Commerce Department’s Bureau of Industry and Security (BIS). The report lays...more

Treasury Department Announces Largest Settlement in History and Severe Penalties Against Binance

On November 21, 2023, the Treasury Department, through the Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC), announced unprecedented actions against Binance Holdings Ltd. (Binance) and...more

Annual Report to Congress Proposes Counters to China’s Military-Civil Fusion Program

On November 14, 2023, the U.S.-China Economic & Security Review Commission (the Commission) published its annual report to Congress. The report covers a wide range of topics, including a detailed assessment of the state of...more

U.S. Temporarily Eases Sanctions Against Venezuelan Energy, Gold

On October 18, the Treasury Department’s Office of Foreign Assets Control (OFAC) eased U.S. sanctions on dealings with Venezuela’s gold and oil and gas sectors by issuing and amending several general licenses. According to...more

U.S. Agencies Release Xinjiang Supply Chain Business Advisory Addendum

On September 26, 2023, the U.S. Department of State, the U.S. Department of the Treasury, the U.S. Department of Commerce, the U.S. Department of Homeland Security, the U.S. Department of Labor, and the Office of the U.S....more

U.S. and EU Regulators Provide Insights on Sanctions and Export Evasion Risks

On September 11, 2023, the Financial Crimes Enforcement Network (FinCEN) issued a Financial Trend Analysis detailing trends in suspected evasion of export controls on Russia. FinCEN’s analysis is informed by reports provided...more

U.S. Bureau of Industry and Security Creates Option for Extended Renewals of Temporary Denial Orders

On August 30, 2023, the Department of Commerce’s Bureau of Industry and Security (“BIS”) amended the Export Administration Regulations (“EAR”) to allow for the extended renewal of Temporary Denial Orders (“TDOs”) under...more

New Nuclear Nonproliferation Controls on China and Macau

On Monday, August 14, 2023, the Commerce Department will impose new nuclear nonproliferation (“NP”) controls on China and Macau. The new controls are meant to address ongoing U.S. Government concerns regarding U.S. nuclear...more

White House Issues Executive Order on Outbound Investment Screening

On August 9, 2023, the White House issued Executive Order 14105 (“EO”) to address the national security threat posed by outbound investment in certain countries of concern that seek to develop and exploit sensitive or...more

Treasury Department Releases 2022 Annual CFIUS Report

On July 31, 2023, the U.S. Treasury Department released its Annual Report to Congress on the Committee on Foreign Investment in the United States (“CFIUS” or “the Committee”), covering the 2022 calendar year (the “Report”). ...more

Federal Agencies Publish Tri-Seal Official Guidance on Voluntary Self-Disclosure of Violations

On July 26, 2023, the U.S. Department of Justice (“DOJ”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), and the U.S. Department of Treasury’s Office of Foreign Asset Control (“OFAC”) released a...more

Senate Bill Proposes to Curb Export Licenses and Impose “Flow Down” Entity List Restrictions

On June 22, 2023, Senators Rubio (R-FL) and Wicker (R-MS) – the top Republicans on the Select Committee on Intelligence and the Armed Services Committee, respectively – introduced S. 2170, the Depriving Enemy Nations of...more

OFAC Issues Africa Gold Advisory

On June 27, 2023, the Treasury Department’s Office of Foreign Assets Control (“OFAC”), in conjunction with USAID, and the Departments of Commerce, Homeland Security, and Labor, published an Africa Gold Advisory identifying...more

European Union Adopts 11th Round of Sanctions Against Russia

On June 23, 2023, the EU adopted its latest round of Russia sanctions. The new regulations have a focus on combatting circumvention and evasion, following suit with similar measures adopted by the United States last month....more

OFAC Revamps and Updates Website

On April 3, 2023 the Office of Foreign Assets Control (“OFAC” or “the agency”) launched a new domain for its website at ofac.treasury.gov. This update aims to make it easier for users to navigate OFAC’s sanctions database,...more

Anniversary Round of U.S. Sanctions, Export Controls Impose and Enhance Restrictions Against Financial and Material Support for...

Last Friday, on the anniversary of the Ukraine invasion, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) took significant action by imposing sanctions against the Russian economy, targeting Russia’s...more

Initial Restructuring of the International Traffic in Arms Regulations

As part of a comprehensive streamlining effort, the U.S. State Department’s Directorate of Defense Trade Controls (DDTC) issued an interim final rule that reorganizes and restructures Part 120 of the International Traffic in...more

European Union Adopts Eighth Package of Sanctions Against Russia

Yesterday, the European Union implemented its eighth round of sanctions on Russia in response to Russia’s claimed annexation of Ukrainian territory. This latest package includes expanded import and export restrictions, an...more

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