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
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
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
Over the course of this year, the U.S. government has enacted a number of new regulatory changes, including changes aimed at addressing national security concerns related to countries of interest, including China, Russia, and...more
While the pandemic has slowed down many things this year, it did not impede progress by the Department of Commerce’s Bureau of Industry and Security (“BIS”) in publishing various regulatory changes aimed at addressing...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
The US Department of Commerce, Bureau of Industry and Security (BIS) issued a final rule amending the license review policy for items on the Commerce Control List that are controlled for national security (NS) reasons and are...more
Hong Kong Updates and Alerts - New Restrictions on Exports to Hong Kong – License Exceptions for Hong Kong Suspended - On June 29, 2020, the State Department announced that the U.S. will end the export of U.S.-origin...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
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
After almost a year of speculation and discussion, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) is further tightening controls on exports, reexports, and transfers in-country (collectively,...more
On 28 April the U.S. Commerce Department, Bureau of Industry and Security published two final rules and a proposed rule amending the Export Administration Regulations that will further restrict and regulate transactions...more
In yet another action on April 28, 2020, the Bureau of Industry and Security (BIS) issued a final rule imposing stricter license requirements on a wide range of exports, reexports and transfers to China, Russia, or Venezuela...more
In a burst of activity, the US Department of Commerce, Bureau of Industry and Security (BIS) issued two final rules and one proposed rule. These rules, published in the Federal Register on April 28, 2020, made a series of...more