On August 15, 2024, the U.S. Department of Commerce’s Office of Export Enforcement (“OEE”) announced the settlement of the latest administrative enforcement action involving TE Connectivity Corporation—a Pennsylvania-based...more
Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance to exporters intended to further assist BIS in its efforts to crack down on third-party diversion to Russia. ...more
On July 18, 2024, the U.S. Dept. of Commerce, Bureau of Industry and Security (BIS) published a new interim final rule (the “Interim Final Rule”) entitled “Standards-Related Activities and the Export Administration...more
Typically, the Bureau of Industry and Security (BIS) within the U.S. Department of Commerce administers export controls on end users by designating those persons on one of its public screening lists—e.g., the Unverified List,...more
On July 10, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released new guidance (the “July 10 Release”) outlining different types of precautionary letters (“supplier list” letters, “Project...more
On July 18, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule (IFR) amending the U.S. Export Administration Regulations (EAR) so that certain technology and software...more
The U.S. government’s primary export control regulator – the Bureau of Industry and Security (BIS) within the Commerce Department – issued a new rulemaking to remove barriers from U.S. companies’ participation in...more
On July 9, 2024, the Forced Labor Enforcement Task Force (FLETF) issued its annual update to its guidelines enforcing the Uyghur Forced Labor Prevention Act (“UFLPA”) in a Report to Congress titled “2024 Updates to the...more
As we pass the midpoint of a year marked by assertive enforcement of dual use laws, the Department of Commerce’s Bureau of Industry and Security (BIS) published an updated version of its Don’t Let This Happen to You! Guide....more
On June 27, 2024, the U.S. Department of Commerce, Bureau of Industry & Security (BIS) announced its first update to the boycott requester list. The list contains entities that have been reported by a U.S. person as having...more
On June 20, the Department of Commerce’s Bureau of Industry and Security (BIS) for the first time banned a software and cybersecurity company using authority provided by June 2023’s “Protecting Americans’ Sensitive Data from...more
We are seeing a steady increase in client imports being detained at port by U.S. Customs and Border Protection (CBP) on grounds of alleged forced labor in the supply chain....more
On June 12, 2024, the U.S. Department of Treasury (Treasury), U.S. Department of State (State), and U.S. Department of Commerce (Commerce) announced another round of sanctions and export controls targeting Russia. In this...more
We all know what a “core” sanctions violation looks like. The heartland of such misconduct has been described on numerous occasions in OFAC enforcement actions and settlements. In this environment, however, companies have...more
Citing Russia’s “transition to a full war economy,” the United States imposed sweeping new sanctions and export controls on Russia and Belarus today, including companies and individuals that continue to supply Russia’s...more
On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new measures targeting Russia’s financial infrastructure, including: 1. Expanding the scope of financial sanctions:...more
On May 16, 2024, the Department of Homeland Security announced that it is adding twenty-six entities to the Uyghur Forced Labor Prevention Act (“UFLPA”) Entity List, the consolidated register of four lists required by section...more
In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. ...more
Medical device companies have a new regulatory pathway for exporting certain U.S.-origin medical products to Russia, Belarus, Crimea and other regions of Ukraine (i.e., the so-called Donetsk People’s Republic and Luhansk...more
On April 22, 2024, the U.S. Department of Justice announced the indictment of 10 Venezuelan individuals for conspiring to violate the International Economic Emergency Powers Act (“IEEPA”). According to the DOJ, the...more
On April 5, the Department of Homeland Security (DHS) announced a plan to crack down on illicit trade in the textile industry. The announcement comes as DHS has been urged, especially by the textile industry, to more...more
U.S. Customs authorities impounded thousands of vehicles, showing risks to imports linked to forced labor. The U.S. government detained thousands of luxury vehicles deemed to contain a small electronic component sourced from...more
February saw a continuing focus on Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC), in conjunction with the State Department, sanctioned over 500 individuals and entities – the “largest number...more
Proposed federal legislation known as the BIOSECURE Act is being considered in both the U.S. House of Representatives and the U.S. Senate....more
The Uyghur Forced Labor Prevention Act (UFLPA) was signed into law in December 2021 to address the use of forced labor in Xinjiang, China. It establishes a rebuttable presumption that the importation of any goods, wares,...more