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President Trump Places His Early Mark on Export Controls

Howard Lutnick has been confirmed as Secretary of Commerce, while Jeffrey Kessler has been nominated for Under Secretary for Industry and Security. Both have more experience with trade policy and tariffs than with export...more

First Significant Changes in Over a Decade to US Export Controls on Space-Related Items and Activities

U.S. export controls on space-related items were last significantly revised in 2014. Since then, the industry has continued to evolve towards a wider range of public-private partnerships and purely commercial activities,...more

Significant New U.S. Person and Other Export Controls Proposed Regarding Military, Intelligence, and Security End Users

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has published proposed amendments to the Export Administration Regulations (EAR) that would significantly expand the scope of the export controls over...more

DDTC Proposes ITAR Changes for Australia and the United Kingdom

On May 1, 2024, the State Department’s Directorate of Defense Trade Controls (DDTC) published a proposed rule to amend the International Traffic in Arms Regulations (ITAR) to reduce export authorization requirements for...more

BIS Eliminates Almost All EAR Controls for Australia and the United Kingdom

On April 19, 2024, BIS removed almost all controls over exports and reexports to, and transfers within, Australia and the United Kingdom of items subject to the EAR. The action is the first change to U.S. export control...more

BIS Announces Key Updates to Voluntary Self-Disclosure Process

Key Points - On January 16, 2024, Matthew Axelrod, Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s BIS announced key updates to BIS’s VSD process. The updates are also now reflected on BIS’s...more

Commerce Imposes Significant New Controls on Advanced Semiconductors

On October 17, 2023, the Commerce Department’s Bureau of Industry and Security (BIS) released three rules amending the Export Administration Regulations (EAR) that significantly build on the October 7, 2022 semiconductor...more

Tri-Seal Compliance Note: Voluntary Self-Disclosure of Potential Violations

On July 26, 2023, the departments of Commerce, Justice and the Treasury issued their second ever to date “Tri-Seal Compliance Note” (the “Note”). It describes expectations for the voluntary disclosure of sanctions, export,...more

Russia, China, Semiconductors and Reimagining National Security: US Export Controls 2022 Year in Review

The volume and impact of changes to United States export control regulations in 2022 were unprecedented, and we expect 2023 will likely bring additional changes. This alert provides a summary of key changes, themes and...more

BIS Has New Authorities to Impose Controls over Activities of US Persons in Support of Foreign Military, Security, or Intelligence...

Key Points - The Export Control Reform Act of 2018 has been amended to give BIS the authority to regulate services and other activities of U.S. persons, wherever located, when in support of foreign “military, security, or...more

BIS Imposes New Controls to Limit the Development and Production of Advanced Computing and Semiconductor Capabilities in China

The Commerce Department’s Bureau of Industry and Security (BIS) has amended the Export Administration Regulations (EAR) to impose a series of significant new export controls designed to limit the development and production in...more

BIS Announces Significant Changes to How It Administers Unverified and Entity Lists

Key Points - BIS amended the EAR to add a new criterion for placing a party on the Entity List: a sustained lack of cooperation by the host government to schedule and facilitate the completion of an end-use check of an...more

U.S. Government Imposes Expansive, Novel and Plurilateral Export Controls Against Russia and Belarus

Key Points - As part of highly coordinated U.S. government and allied and partner country responses to Russia’s further invasion of Ukraine, and Belarus’ enabling of it, BIS imposed on February 24, 2022, and March 2,...more

US Government Clarifies, Reorganizes and Renames Descriptions of How Foreign-Produced Items Outside the United States Are Subject...

Key Points - The U.S. Department of Commerce has reorganized and clarified the regulations describing when foreign-produced items outside the United States are and are not subject to the licensing and other obligations of...more

Biden Administration Issues New Sanctions and Export Controls to Respond to Coup in Burma

Key Points - On February 11, 2021, in the first deployment of sanctions since assuming office, President Biden issued EO 14014, authorizing sanctions against members of the Burmese military and related parties responsible...more

BIS Announces the Elimination of License Exception CIV, Expanded Licensing Requirements on Exports to Chinese, Russian, and...

- On April 28, 2020, the Bureau of Industry and Security of the U.S. Department of Commerce announced changes to the Export Administration Regulations (EAR) through three notices published on the Federal Register. The changes...more

Export Control Reform Offers Revisions to Key Terms, and DDTC Increases Penalty Authority; More Work Remains (Part 1)

On June 3, 2016, the U.S. Department of State, Directorate of Defense Trade Controls (DDTC) and the Department of Commerce, Bureau of Industry and Security (BIS) issued changes to the International Traffic in Arms Regulations...more

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