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US Blocks More Russian Elites, Imposes Import Restrictions on Energy & More, Adds Export Controls on Luxury Goods

Watch Out, More Things Are Luxury Than You Think! On March 11, 2022, the President issued Executive Order 14068 (EO 14068) Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian...more

Commerce Launches Rulemaking Process on Foundational Technologies, Hints at Three Potential Areas of Control

BIS will be looking at items that are controlled only for anti-terrorism, crime control, short supply, United Nations embargoes, or designated as EAR99 in establishing new Foundational Technologies Controls. Two years...more

US Sanctions on Chinese Apparel Companies for Forced Labor Hit Retail Supply Chains

There is a risk that garments made from cotton produced by XPCC could be subject to a Customs and Border Protection withhold release orders. Fashion and luxury goods companies need to be concerned about the recent...more

Pentagon Identifies 20 ‘Communist Chinese Military Companies’

As the US technology competition with China continues to intensify, the Trump Administration has taken another step to tighten the screws on China. In late June, the US Department of Defense (DoD) made public a list of 20...more

OFAC Illuminates Its Most Recent Iran Sector-Based Sanctions

In four new FAQs issued on June 5, OFAC provides a few surprises in its clarifications of the sector-based sanctions contained in Iran-related Executive Order 13902, which was issued this past January. The new FAQs confirm...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

BIS Imposes Additional Cuba Trade Restrictions and Restricts Use of Temporary Sojourn License Exception for Multiple Countries

BIS has restricted Cuba’s access to commercial aircraft and other goods, lowered de minimis for foreign items containing US content to 10%, and restricted the temporary sojourn by aircraft in Iran, Syria, Sudan, and North...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

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