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
7/5/2022
/ Blocking Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
FinCEN ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
State-Owned Enterprises ,
Supply Chain ,
Ukraine
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
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
On March 31, to address rising energy prices in the U.S. and globally, the Biden administration announced a record release from the Strategic Petroleum Reserve, of roughly one million barrels per day, every day for the next...more
On March 8, 2022, the United States, United Kingdom, and European Union announced measures intended to eliminate or reduce their reliance on Russian energy imports. Until now, these countries had largely refrained from...more
On February 24, 2022, the US Government imposed severe economic sanctions and export controls on Russia. The restrictions consist of two parts: 1) significant financial sanctions on a range of Russian financial institutions...more
On February 8, 2022, the Bureau of Industry and Security (“BIS”) published a Final Rule amending the Export Administration Regulations (“EAR”) to add 33 persons to the Unverified List (“UVL”) pursuant to § 744.15(c) of the...more
The Court of Justice of the EU has interpreted for the first time the Blocking Regulation. The ruling confirms that it is possible to terminate contracts with a US designated person without providing reasons. However, in...more
On December 23, 2021, President Joe Biden signed into law the Uyghur Forced Labor Prevention Act (“UFLPA”). Most notably, the UFLPA strengthens the enforcement of Section 307 of the Tariff Act of 1930 by imposing a rebuttable...more
1/7/2022
/ Biden Administration ,
Child Labor ,
Corporate Social Responsibility ,
Customs and Border Protection ,
Export Controls ,
Forced Labor ,
Goods or Services ,
Human Rights ,
Imports ,
New Legislation ,
Office of Foreign Assets Control (OFAC) ,
Supply Chain
The release of data to a foreign person, even within U.S. borders, is deemed by U.S. export control laws to be an export to the recipient's country of permanent residency or citizenship. The delivery of U.S. export-controlled...more
The decision to pay millions to a cyber criminal has never been easy, but it is now even more complex. The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory on September 21,...more
On 15 April 2021, the U.S. Government announced a number of new sanctions measures against Russia, targeting a variety of “harmful foreign activities” contrary to U.S. foreign policy. ...more
4/21/2021
/ Biden Administration ,
Crimea ,
Critical Infrastructure Sectors ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
SolarWinds ,
Sovereign Debt ,
State-Owned Enterprises ,
Technology Contracts
On 15 January 2021, the Bureau of Industry and Security (BIS) published an interim final rule imposing new restrictions requiring licenses for transactions involving exports, reexports, or transfers, as well as certain...more
On 18 December 2020, BIS added over 70 entities to the Entity List, including Semiconductor Manufacturing International Corporation (SMIC) of China. Most of these entities are subject to a presumption of denial for licenses...more
On 19 September 2020, China's Ministry of Commerce (MOFCOM) published the Provisions on the Unreliable Entity List (Order No.4 of 2020) (provisions), which immediately came into effect. It has been over one year since MOFCOM...more
The Cuban Assets Control Regulations have been amended to prohibit U.S. persons from lodging at certain properties in Cuba, incorporate restrictions on imports of Cuban alcohol and tobacco, and revoke general licenses...more
On 14 July, the same day the president signed into law the Hong Kong Autonomy Act (the act), President Trump issued the Executive Order on Hong Kong Normalization (the EO) directing federal agencies to impose a range of trade...more
On June 28, 2010, the Standing Committee of China's National People's Congress (NPC) reviewed the second draft of China's Export Control Law (the "Law"). Six months had passed since the Law was first reviewed by the NPC in...more
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
On 22 June President Trump signed the Proclamation Suspending Entry of Aliens Who Present a Risk to the U.S. Labor Market Following the Coronavirus Outbreak. This executive action extends the president's April 2020 suspension...more
6/28/2020
/ Coronavirus/COVID-19 ,
Foreign Nationals ,
Foreign Workers ,
H-1B ,
H-2B ,
Immigration Procedures ,
J-1 Visas ,
L-1 Visas ,
Non-Immigrant Visas ,
Presidential Proclamations ,
Trump Administration ,
Visas
On 24 June 2020, the United States Department of Defense made public a list of Chinese companies operating in the U.S. that are associated with the Chinese military. ...more
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
On 27 May 2020 U.S. Secretary of State Pompeo certified to Congress that the State Department no longer considers Hong Kong to have significant autonomy from China and therefore "Hong Kong does not continue to warrant...more
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
5/18/2020
/ Bureau of Industry and Security (BIS) ,
China ,
Comment Period ,
Commerce Control List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
Huawei ,
Prohibited Transactions ,
Supply Chain ,
Telecommunications ,
U.S. Commerce Department
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