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Current State of BIS Export Controls in Response to the Russian Federation's Invasion of Ukraine

Since February 24, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has implemented numerous new export control restrictions in response to the invasion of Ukraine by the Russian Federation...more

United States Continues to Increase Sanctions Against Russia and Belarus

On March 11, 2022, President Biden signed an Executive Order prohibiting exports of US-origin luxury goods to Russia and Belarus and Russian and Belarusian oligarchs, broadening the US import ban on goods originating in the...more

New Key Developments in Response to Russia's Invasion of Ukraine

The United States and the European Union imposed additional sanctions this week in response to the Russian Federation’s invasion of Ukraine and the United States announced its intention to make sanctions enforcement a...more

US and Foreign Companies Now Subject to Expansive US License Requirements for Business with Russia

On February 23 and 24, 2022, the United States, through the Department of Commerce’s Bureau of Industry and Security (“BIS”) and the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), took significant...more

CFIUS Issues Regulations for FIRRMA Pilot Program

On Oct. 10, 2018, the U.S. Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (CFIUS or the Committee), issued interim regulations (the Regulations) setting forth the scope of,...more

New Sanctions Against Russia Have Unfavorable Impact on Defense Sector, with Carve-Outs Favoring Certain Aspects of the Aerospace...

On Aug. 27, 2018, the U.S. State Department published new sanctions against Russia based on the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act) after determining that the government of...more

U.S. Sanctions Under the Trump Administration – International Trade Implications

The Trump Administration has been active on the sanctions front as a means of asserting U.S. foreign policy and national security interests. Congress has also taken an increasingly active and direct role of late, beyond its...more

White House Imposes Sanctions in Response to Malicious Russian Cyber Activity

On Dec. 29, 2016, in response to the Russian government’s “aggressive harassment of U.S. officials and cyber operations aimed at the U.S. election,” President Obama issued an Executive Order Taking Additional Steps to Address...more

DOJ Publishes Guidance Encouraging Voluntary Self-Disclosures, Full Cooperation and Timely and Appropriate Remediation

On Oct. 2, 2016, the U.S. Department of Justice (DOJ), National Security Division (NSD) published Guidance setting forth its policy of encouraging business organizations to voluntarily self-disclose criminal violations of...more

BIS and DDTC Harmonize Destination Control Statements, Make Other Clarifying Changes

On Aug. 17, 2016, as part of the President’s Export Control Reform (ECR) initiative, the Department of Commerce, Bureau of Industry and Security (BIS) and the Department of State, Directorate of Defense Trade Controls (DDTC)...more

BIS And DDTC Revise Controls on Export of Toxicological Agents and Directed Energy Weapons

On July 28, 2016, the Department of Commerce’s Bureau of Industry and Security (BIS) and the Department of State’s Directorate of Defense Trade Controls (DDTC) issued final rules implementing revisions to U.S. export controls...more

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