New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more
1. Seagate Technology Gets Largest-Ever BIS Penalty for Sales to Huawei- Seagate Technology LLC recently incurred a $300 million civil penalty from U.S. Department of Commerce’s Bureau of Industry and Security (BIS) due to...more
On May 19, the Bureau of Industry and Security (BIS) issued two final rules expanding the export controls in the Export Administration Regulations (EAR) against the Russian Federation (Russia) for its continued war with...more
On May 19, 2023, the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced new export controls and Entity List additions during President Biden’s G7 visit in Japan. In conjunction with the G7 meetings,...more
Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced the issuance of a $300 million penalty against Seagate Technology LLC and its Singapore affiliate, Seagate Singapore International...more
On April 18, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued a policy memorandum clarifying the Office of Export Enforcement’s (OEE) policies encouraging both Voluntary Self-Disclosures...more
Matt Axelrod, the Assistant Secretary for Export Enforcement, at the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce, must be grinning with satisfaction that BIS delivered, in a big way, after he...more
On February 24, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced four new rules expanding restrictions on exports to Russia and Belarus. The revisions to the Export Administration...more
On Monday, February 13, 2023, the U.S. government will officially issue a stricter policy of denial for providing lower-tech items to Huawei. Technological containment continues as the Netherlands and Japan move to impose...more
The year 2022 saw a substantial increase in export restrictions applicable to China. The U.S. and China are not only in a trade war but there is also an effort by the U.S. to (1) prevent development of supercomputers,...more
On December 16, 2022, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) published a rule adding 35 entities from China and one entity from Japan to the Entity List for supporting China’s military...more
On December 15, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced that it is adding 36 primarily Chinese entities, including Chinese memory chip maker Yangtze Memory Technologies and...more
On October 28, 2022, on the eve of the mid-term elections, a bill was introduced in the House that, unless you are an export control/compliance nerd, most would not have given it any thought. This bill, H.R. 9241, called the...more
On October 7, the Department of Commerce, Bureau of Industry and Security (BIS), announced new controls on exports to China related to semiconductors. BIS also added 38 Chinese entities to the Unverified List (UVL) and...more
This blog post covers several new sanctions and export controls that the U.S. government imposed on Russia and Belarus in the time period occurring between March 31, 2022 and April 21, 2022. ...more
As Russia’s invasion of Ukraine continues, the White House countered with another wave of sanctions and export controls. Building on the restrictions discussed in our Phase I and Phase II alerts, these new measures further...more
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
On February 3, 2022, the Commerce Department published a final rule amending the Export Administration Regulations (“EAR”) to clarify the scope of the foreign-direct product rule (“FDPR”). The FDPR expands the jurisdiction...more
On May 15, 2020, the Department of Commerce Bureau of Industry and Security (BIS) issued an interim rule (“Interim Rule”) significantly expanding its control of certain foreign-produced items when there is “knowledge” that...more
- The U.S. Department of Commerce has published a highly complex and novel interim final rule extending the controls of the Export Administration Regulations (EAR) over foreign-made items in Huawei’s contract manufacturing...more
On Friday, May 15, 2020, the Department of Commerce and the Bureau of Industry and Security (BIS) revised an arcane export control rule that imposes US export controls on foreign-origin products (hardware, software, and...more
In response to the announcement on Friday by the U.S. Department of Commerce of new export-related restrictions targeting Huawei Technologies Co., Ltd. and several of its non-U.S. affiliates (collectively, Huawei), Sen. Ben...more