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
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
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 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
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
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
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
I. US SANCTIONS - US Department of the Treasury Sanctions Almost 300 Individuals and Entities: On February 23, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned almost 300 individuals...more
Following the invasion of Ukraine by Russia on February 24, 2022, the United States ("US"), the European Union ("EU"), and the United Kingdom ("UK") adopted—together with their allies—successive waves of sanctions, in an...more
On February 23, 2024, marking the two-year anniversary of Russia’s invasion of Ukraine, the U.S. Departments of Commerce, State, and Treasury announced new U.S. sanctions and export controls targeting Russia. In addition, the...more
On February 23, 2024, on the brink of the two-year anniversary of Russia’s invasion of Ukraine, President Biden announced additional sanctions and export controls against Russia and entities in third countries that have...more
You are reading the November 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. ...more
For the second year running, and in what may prove to be a regular process, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has significantly expanded export controls on specific semiconductor and...more
On October 25, 2023, the Bureau of Industry and Security (“BIS”) published interim final rules amending the Export Administration Regulations (“EAR”) to add/clarify new controls on semiconductor manufacturing equipment...more
On November 6, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) held a public briefing to address industry questions concerning the latest export controls on advanced computing and semiconductor...more
1. BIS Releases Texts of New Chip Export Control Rules- Updating and expanding on rules issued last year, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released three rules on October 27 targeting...more
On October 17, 2023, the U.S. Department of Commerce Bureau of Industry & Security (“BIS”) released three rules amending the Export Administration Regulations (“EAR”) to strengthen export controls on advanced computing...more
The new measures build on sweeping restrictions that the United States introduced in October 2022. On October 17, 2023 — just over a year after introducing extensive regulations aimed at restricting parties in China from...more