During the first quarter of 2024, there were significant developments in the U.S. sanctions framework. This report summarizes the key developments and provides links to the relevant sources....more
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
October saw two major enforcement actions involving Russia. First, three individuals were indicted for facilitating the export of controlled U.S.-origin electronics to Russia. Second, the president of a U.S. steel trading...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 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
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
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
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
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
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
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
Three important regulatory developments were published yesterday in the Federal Register by the Commerce Department’s Bureau of Industry and Security...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
The U.S. Department of Commerce's Bureau of Industry and Security (BIS) on April 28, 2020, published two final rules and one proposed rule that amend the Export Administration Regulations (EAR), with the goal of limiting the...more