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OFAC lifts certain sanctions on Syria, broad export controls remain in place

General License (GL) 25 authorizes transactions previously prohibited by various regulations. Specifically, Section (a) broadly authorizes activities previously prohibited under the Office of Foreign Asset Control (OFAC)’s...more

U.S. Department of Commerce expands controls on advanced semiconductors and establishes new controls on closed AI model weights

The new interim final rule imposes new global licensing requirements for ECCNs 3A090.a, 4A090.a, and corresponding .z items; controls for closed AI model weights; updated data center validated end-user authorizations;...more

Significant new measures against Russia issued by US Departments of Treasury, State, and Commerce

On 12 June 2024, the US Departments of Treasury, State, and Commerce imposed new restrictions targeting Russia, including: (i) restricting the provision of certain information technology and software services to Russia...more

Statute of limitations extended for violations of U.S. sanctions

Congress has doubled the statute of limitations for violations of most U.S. sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control.  Companies should be aware of the...more

BIS Issues License Exception MED for Russia, Belarus, Crimea, and covered regions of Ukraine

On April 29, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule to add a new license exception for medical devices (License Exception MED) to authorize the export, reexport, and...more

U.S. Department of Commerce issues new resource to facilitate antiboycott compliance

On 28 March, the U.S. Commerce Department, Bureau of Industry and Security (BIS) published a list of entities that have been identified as having made a boycott-related request in order to help U.S. companies, including...more

U.S., EU, and UK expand sanctions to mark the second anniversary of Russia’s war in Ukraine

Following the death of political activist Aleksey Navalny and to mark the second anniversary of Russia’s invasion of Ukraine, the United States, EU and UK adopted a series of amendments to their respective economic sanctions...more

BIS Issues Three New Rules To Ease Certain Export Licensing Requirements

On December 8, 2023, the Bureau of Industry and Security (BIS) issued three separate rules to amend the Export Administration Regulations (EAR) to liberalize several categories of export licensing requirements and make...more

U.S. implements new export controls on toxins, plant pathogens and biological equipment

The United States Department of Commerce’s Bureau of Industry and Security has issued regulations to amend the Export Administration Regulations to implement changes to controls of certain viruses, marine toxins, plant...more

U.S. Government seeks to restrict biotechnology cooperation with China

The United States government is increasingly scrutinizing U.S. industry’s reliance on China for biotechnology research and development and manufacturing, and is taking steps to expand export control requirements on China that...more

BIS imposes significant new export controls on China regarding semiconductors and supercomputers

The Department of Commerce’s Bureau of Industry and Security has issued an interim final rule to deny China’s access to certain semiconductor and advanced computing technology and to inhibit China’s ability to manufacture...more

U.S. prohibits imports of Russian gold and imposes new sanctions in latest measures against Russia

The U.S. Government has imposed additional punitive measures against Russia in response to Russia’s actions in Ukraine.  The new measures include a prohibition on imports of Russian gold into the United States, new SDN and...more

BIS continues to expand export controls on Russia and Belarus and adds 71 entities to the Entity List

On 2 June 2022, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) issued two final rules, effective on the same day, that revised the Export Administration Regulations (“EAR”) pertaining to the U.S.’s...more

OFAC Authorizes Transactions in Listed Sectors in Connection with Non-Regime Held Areas of Syria

The Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) No. 22 on May 12, 2022, authorizing transactions that are ordinarily incident and necessary to activities that occur in specified, non-regime held...more

U.S. expands controls on exports of industrial and commercial goods to Russia

The U.S. Bureau of Industry and Security (“BIS”) has expanded export controls relating to Russia. The final rule imposes license requirements for exports, reexports and transfers to/within Russia on several items with...more

BIS issues frequently asked questions to clarify the military end use/user rule

On 29 June 2020, the final rule expanding the military end user/user controls (MEU) issued by the Bureau of Industry and Security (BIS) went into effect. On 26 June 2020, BIS issued an FAQs guidance document that provides...more

China Entity List designations

On Friday, May 22, 2020, the US Department of Commerce, Bureau of Industry and Security (BIS) announced in two separate press releases that it would be adding a number of companies and governmental entities to the Entity...more

BIS Expands Foreign-Produced Direct Product Rule With Regard to Huawei

The Commerce Department’s Bureau of Industry and Security has announced an Interim Final Rule amending the Export Administration Regulation’s General Prohibition Three, the foreign-produced direct product rule....more

U.S. Department of Commerce imposes significant new export control restrictions on China, Russia, and Venezuela

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

BIS adds a number of companies to the Entity List, including Iran Air

As of 16 March 2020 Iran Air and a number of other entities were placed on the Bureau of Industry and Security's (BIS) Entity List. Summary - Companies that use Iran Air as transport, particularly companies engaging in...more

BIS revises Country Group designations for Russia and Yemen, imposing additional licensing requirements and removing availability...

On 24 February 2020 the Bureau of Industry and Security (BIS) of the U.S. Department of Commerce published a final rule amending the Export Administration Regulations (EAR) and imposing additional export licensing...more

U.S. imposes strict export controls on certain artificial intelligence software for automating the analysis of geospatial imagery

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) published an interim final rule on 6 January 2020 imposing licensing requirements on certain artificial intelligence software specially designed to...more

BIS issues final rule restricting additional exports and reexports to Cuba

On 21 October 2019 the Bureau of Industry and Security (BIS) issued a final rule amending Cuba-related provisions in the Export Administration Regulations (EAR). The new rule further restricts exports and reexports of...more

New Huawei Entity List designations, TGL extension, exclusions, and certification changes

The U.S. Commerce Department's Bureau of Industry and Security (BIS) is extending the temporary general license (TGL) for Huawei until 18 November 2019, and adding additional Huawei companies to the Entity List....more

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