The sanctions world experienced another action-packed year in 2023. Sanctions against Russia dominated the year in terms of the number of designations and new restrictions, and the attacks perpetrated by Hamas in Israel on 7...more
In the nearly eighteen months since the Russian invasion of Ukraine, many companies have had to reanalyze their export control compliance procedures, particularly with respect to countries with adversarial or strained...more
The centrality of international trade laws in the development and execution of U.S. foreign policy has never been more evident than in 2022. Companies that have not invested in international trade compliance programs are...more
The American Conference Institute is hosting their 17th Annual Flagship Conference on U.S. Economic Sanctions Enforcement and Compliance on April 25-26, 2023, in Washington! Don’t miss the opportunity to stay current with the...more
Russia - Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating U.S. Sanctions on Russia (DOJ) Those involved. Charles McGonigal, former Special Agent in Charge of the FBI...more
This is the fifth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in State AG enforcement. Up next: SEC Enforcement in 2022: A Look Ahead. ...more
The U.S. Government is continuing its frequent and highly visible use of denied party lists as an important tool in administering the export control laws. Each of the Bureau of Industry and Security (BIS), the Office of...more
In addition to compliance considerations under US sanctions associated with activities of U.S. persons, companies should also ensure that their compliance programs take into account the expansion under U.S. export controls of...more
This is the second in our First 100 Days series examining important trends in white collar law and investigations in the early days of the Biden administration. Our previous entry discussed SEC enforcement. Up next,...more
There’s been a non-stop bombardment of recent export amendments involving China and other “countries of concern” within the last six months. The main driver behind these has been the U.S. Government’s concern about the...more
Companies should be prepared to conduct additional due diligence for any transactions involving entities in the countries enumerated in this rule. In an interim rule published on, January 15, 2020, the Department of...more
Despite a shift in the sanction landscape, it will take time for enforcement activity to catch up. As a result, organizations should regularly examine their exposure with business partners around the globe and consult with...more
On January 14, 2021, the U.S. Department of Commerce issued an interim final rule to address national security, economic security, and public health and safety concerns related to Information and Communications Technology and...more
Rounding out an already-intense 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued three notices in December that expanded export sanctions and restrictions against Chinese, Russian, and...more
Turning to the business of exports from the United States, the next section is a must-read for any company doing business in the United States or from the United States. Or for that matter, any company competing with affected...more
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule effective October 29, 2020 amending Section 742.4(b)(7) of the Export Administration Regulations (“EAR”) to revise the license...more
The Commerce Department’s Bureau of Industry Security (“BIS”) issued a final rule to restrict even further export licenses for National Security (“NS”) controlled items for China, Venezuela and Russia....more
This quarter, the U.S. announced new sanctions and trade restrictions on China in response to its perceived intrusions on Hong Kong’s autonomy and reported human rights abuses in Xinjiang. The Trump Administration acted...more
On June 29, 2020, the Commerce Department issued 32 Frequently Asked Questions (FAQs) concerning revision - effective as of the same date - to Part 744.21 of the Export Administration Regulations (EAR). As we discussed in a...more
As previously discussed, on April 28, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced significant changes to the Export Administration Regulations (EAR) to further restrict transactions...more
On April 28, 2020, the US Commerce Department’s Bureau of Industry and Security (BIS) issued a final rule amending provisions of the Export Administration Regulations (EAR) that further restrict exports to military end uses...more
Bureau of Industry and Security Issues Guidance on Rule The new Bureau of Industry and Security (“BIS”) rule prohibiting certain exports, reexports, and transfers of items to “military end-users” and “military end-uses” in...more
The U.S. Department of Commerce, Bureau of Industry and Security (BIS) released impactful new rules on April 28, 2020, that significantly heighten controls on exports to China, Russia, and Venezuela under the Export...more
On April 28, 2020, the US Commerce Department's Bureau of Industry and Security (BIS) published two new final rules amending the Export Administration Regulations (EAR). One of the final rules removes license exception Civil...more
The Commerce Department adopted a number of new amendments to the Export Administration Regulations (EAR) which increase export restrictions for China, Russia and Venezuela. These are part of the Administration’s accelerating...more