High Crimes and Misdemeanors: Federal Criminal Aviation Cases From 2021
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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
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
Key Points - - In an August 2 press release, the US Commerce Department updated its list of aircraft that have flown into Russia or Belarus in apparent violation of Export Administration Regulations by adding the first 25...more
Key Points - - In a March 30 press release, the US Commerce Department updated its March 18 list of aircraft that have flown into Russia in apparent violation of Export Administration Regulations by adding 73 aircraft and...more
On March 30, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) modified and expanded a list of aircraft that have flown into Russia in apparent violation of the Export Administration Regulations...more
On Friday, March 18, 2022, in response to the continued escalation in Ukraine, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) identified both private and commercial aircraft that have flown to Russia...more
This alert summarizes the current state of trade measures and restrictions against both Russia and Belarus, following our last update on February 25, 2022....more
Following the events in Ukraine, various measures have been put in place by the EU, the UK and the US that are expected to have a considerable impact on the aviation and aircraft financing industry. Below we give a round-up...more
Please note: This Holland & Knight alert has been updated on Sept. 13, 2021, with additional information. In plain English, anytime an aircraft departs the United States, this is an "export" and will fall in one of two...more
There are two common types of aircraft exports: 1) permanent exports – where the aircraft is physically exported (i.e., flown) from the U.S. as part of a sale, lease or transfer of possession and control to a foreign person,...more
On 24 February 2020 the Bureau of Industry and Security (BIS) of the U.S. Department of Commerce published a final rule amending the Export Administration Regulations (EAR) and imposing additional export licensing...more
On December 20, 2019, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2020 (“NDAA 2020”), which includes numerous sanctions-related provisions. The law includes the previously introduced...more
On October 21, 2019, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) imposing new sanctions on Cuba for human rights abuses and for its support of...more
• On August 30, DDTC published a final rule that removes many of the radars used in civil automotive and unpiloted aerial vehicles from the USML. • This continues the targeted removal of civil items from the military...more
• The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce's Bureau of Industry and Securities (BIS) announced changes to the Cuban Assets Control Regulations (CACR)...more
In a June 4 announcement, the Trump administration further ratcheted up U.S. sanctions and export controls against Cuba by prohibiting group “people-to-people” travel to Cuba and the use of noncommercial aircraft and...more
Before leaving office, former President Barack Obama signed Executive Order (E.O.) 13761 on Jan. 13, 2017, in response to "positive actions" by the Government of Sudan. E.O. 13761 establishes a basis for complete revocation...more
The U.S. Department of Commerce’s Bureau of Industry and Security recently reached a $115,000 civil settlement agreement with a California-based global technology company on the basis that it violated several export control...more
As described in our April 25, 2013 International Trade & Compliance Advisory, the U.S. government is engaged in a broad export control reform initiative. On October 15, 2013, the first regulatory amendments implementing...more