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
The U.S. Department of State has formally republished the Cuba Restricted List, restoring prohibitions on direct financial transactions with numerous Cuban military, intelligence, and security-linked entities. This move...more
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
The Financial Action Task Force (FATF) has updated its ‘grey list’ of jurisdictions under increased monitoring, removing Senegal and adding Algeria, Angola, Côte d’Ivoire, and Lebanon. The intergovernmental organization made...more
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) recently issued new guidance for financial institutions (FIs) to comply with the Export Administration Regulations (EAR). Released on 9 October 2024, the...more
On July 29, 2024, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) issued a proposed rule to revise the definition of “defense service” and the scope of related controls under existing International...more
The U.S. Department of Commerce’s Bureau of Industry and Security has published a compliance note on voluntary self-disclosure trends and a compendium of export compliance resources targeted to the academic community. The...more
The U.S. Department of Commerce’s Bureau of Industry and Security released an interim final rule (IFR) on July 18th amending the Export Administration Regulations (EAR). This amendment revises the scope of “standards-related...more
On May 15, 2024, the U.S. Commerce Department’s Bureau of Industry and Security issued an antiboycott compliance advisory regarding the Turkish government’s announcement that it will suspend all imports and exports to and...more
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
On April 10, 2024, the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) published guidance for universities and research centers to comply with International Traffic in Arms Regulations (“ITAR”). DDTC...more
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
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has further updated its voluntary self-disclosure (VSD) process by establishing streamlined procedures for minor or technical violations of the Export...more
On December 12, the Select Committee on the Chinese Communist Party of the U.S. House of Representatives issued a comprehensive economic strategy containing over 160 policy recommendations intended to “to fundamentally reset...more
On 6 November 2023, the Department of the Treasury’s Financial Crimes Enforcement Network and the Department of Commerce’s Bureau of Industry and Security issued a joint notice concerning a new Suspicious Activity Report key...more
The U.S. Departments of Commerce, Justice and Treasury have issued a “Tri-Seal” Compliance Note regarding national security laws and regulations and the voluntary self-disclosure of potential violations, highlighting...more
8/2/2023
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Export Administration Regulations (EAR) ,
Export Controls ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
U.S. Treasury ,
Voluntary Disclosure
The US Bureau of Industry and Security has announced that the “Five Eyes” countries have committed to formally coordinate on export controls enforcement. The intelligence alliance member countries hope to increase enforcement...more
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) clarified its policy regarding voluntary self-disclosures and enforcement actions on April 18, 2023. Historically, a failure to voluntarily...more
In 2021, the Export Controls and Human Rights Initiative (“ECHRI”) was launched at the first Summit for Democracy as part of the Presidential Initiative for Democratic Renewal. This year, during the Summit for Democracy 2023...more
On February 16, 2023, the Department of Justice (DOJ) and the Department of Commerce (Commerce) announced the creation of a joint Disruptive Technology Strike Force (Strike Force). The Strike Force will be co-led by the...more
3/7/2023
/ Bureau of Industry and Security (BIS) ,
CFIUS ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Technology Sector ,
U.S. Commerce Department
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
The U.S. Department of State, Bureau of Political-Military Affairs, Directorate of Defense Trade Controls, which regulates the brokering, export, reexport, retransfer, and temporary import of defense articles and services,...more
The International Traffic in Arms Regulations, administered by the U.S. Department of State’s Directorate of Defense Trade Controls, and the Export Administration Regulations, administered by the U.S. Department of Commerce’s...more
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
10/24/2022
/ Biotechnology ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Executive Orders ,
Export Control Reform Act (ECRA) ,
Export Controls ,
FIRRMA ,
National Security ,
Popular ,
Research and Development ,
Technology Sector
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