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President Biden Orders 100-Day Review of America’s Supply Chains for Semiconductors, Batteries, Critical Minerals and APIs

Changes are afoot for key industry sectors with complicated global supply chains. “As this pandemic has made clear, we can never again be in a position where we have to rely on a foreign country that doesn’t share our...more

US Proposes Export Control on Emerging Technology Software to Operate Automated Nucleic Acid Assemblers and Synthesizers

The US Department of Commerce Bureau of Industry and Security (BIS) has proposed a new ECCN, 2D352 to control “software” that is capable of being used to operate nucleic acid assemblers and synthesizers due to concerns the...more

US Government Hurls Another Export Control Grenade at Huawei

On Friday, May 15, 2020, the Department of Commerce and the Bureau of Industry and Security (BIS) revised an arcane export control rule that imposes US export controls on foreign-origin products (hardware, software, and...more

Reference Guide: Worldwide Export Controls on Face Masks and Other Medical Personal Protective Equipment (Updated May 11, 2020)

As the COVID-19 pandemic has expanded exponentially, so too has the demand by hospitals and other healthcare providers for masks and other medical personal protective equipment (PPE) to protect doctors, nurses, and other...more

APR in APRIL, BIS MAY Make Changes to Restrict Re-Exports, Comments Due in JUNE

On April 28, the Bureau of Industry and Security (BIS) issued a proposed rule that would revise License Exception Additional Permissive Re-Exports (APR) to remove a current provision that allows for reexports of items subject...more

Reference Guide: Worldwide Export Controls on Face Masks and Other Medical Personal Protective Equipment (Updated)

As the COVID-19 pandemic has expanded exponentially, so too has the demand by hospitals and other healthcare providers for masks and other medical personal protective equipment (PPE) to protect doctors, nurses, and other...more

FEMA: Certain Exports of Respirators, Masks, and Gloves (PPE) Exempt From Ban

The Federal Emergency Management Agency has left many important questions blowing in the wind as a result of a Notification of Exemptions action published for public inspection on Friday, April 17, 2020. The final action will...more

Reference Guide: Worldwide Export Controls on Face Masks and Other Medical Personal Protective Equipment (Updated)

As the COVID-19 pandemic has expanded exponentially, so too has the demand by hospitals and other healthcare providers for masks and other medical personal protective equipment (PPE) to protect doctors, nurses, and other...more

FEMA Temporarily Halts Exports of Certain PPE

The Federal Emergency Management Agency (FEMA) has exercised its delegated authority under the Defense Production Act (DPA) to issue a temporary final rule (Prioritization and Allocation of Certain Scarce or Threatened Health...more

Maximum Pressure Squared: President Trump Turns His Iran Sanctions Amplifier Up to Eleven

Third-country companies doing business with Iran’s construction, mining, manufacturing, or textiles sectors are now at increased risk of being sanctioned. On Friday, January 10, President Trump issued Executive Order (EO)...more

US Issues First Unilateral Export Control on Artificial Intelligence Software

This software now requires a BIS authorization to be exported or reexported to all countries except for Canada. Companies that develop or use artificial intelligence (AI) to solve geospatial problems or in geospatial...more

ITAR Defense Controls Catches Up to Modern IT, Allowing Exporters to Use Encryption to Protect Defense Technology on the Cloud

The good news is that, for the most part, State resisted the temptation to do something just a little different in the ITAR regulation, so the joint Commerce-State solution works. The chart below provides a quick side-by-side...more

US State Department Seeks Feedback on Amorphous Human Rights Due Diligence for US Exporters of ‘Surveillance’ Items

The US State Department is soliciting feedback on its draft “US Government Guidance for the Export of Hardware, Software, and Technology with Surveillance Capabilities and/or Parts/Know-How,” issued September 4, 2019 (Draft...more

Second Shoe Drops on US Chem-Bio Sanctions on Russia: Did Anyone Hear It?

On Friday, August 2, 2019, the US State Department announced the issuance of another round of sanctions on the Russian Government in relation to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991...more

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