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Parties Engaged in Aircraft Serving Activities: Beware

On Friday, March 18, 2022, in response to the continued escalation in Ukraine, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) identified both private and commercial aircraft that have flown to Russia...more

U.S. Commerce Department Imposes New Export Control Measures Targeting Russia

As previewed by President Biden in his press conference on February 24, 2022, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) is imposing additional export control measures targeting Russia. The new...more

Don’t Forget Expansion Under U.S. Export Controls of Restrictions on U.S. Persons

In addition to compliance considerations under US sanctions associated with activities of U.S. persons, companies should also ensure that their compliance programs take into account the expansion under U.S. export controls of...more

U.S. Imposes Additional Round of Trade Sanctions on Russia

Effective September 7, 2021, the U.S. government imposed a second round of sanctions on Russia in connection with its determination that the Russian Federation violated the Chemical Weapons Convention based on the attack on...more

US, EU Issue Guidance on Expectations for Due Diligence to Address Forced Labor Risks

On July 13, 2021, the US Department of State, US Department of the Treasury, US Department of Commerce, US Department of Homeland Security, Office of the United States Trade Representative, and US Department of Labor issued...more

Antiboycott Updates and Compliance Recommendations

On June 7, 2021, US Department of Commerce, Bureau of Industry and Security (“BIS”) amended its Antiboycott provisions in Part 760 of the Export Administration Regulations (“EAR”) easing reporting requirements and business...more

More End Use/End User Restrictions Coming from BIS

Adding to the challenges of implementing the expanded military end use/end user rule in Part 744.21 of the Export Administration Regulations (“EAR”), restrictions on transactions involving military-intelligence end uses and...more

President Biden Imposes New Sanctions Against Burma Following Coup d’Etat

On February 11, 2021, President Biden issued Executive Order 14014 “Blocking Property with Respect to the Situation in Burma.” As of now, these new sanctions are tailored to target the actors engaged in disrupting the...more

One Administration to the Next: Changes Affecting U.S. Sanctions and Export Controls

While the Trump Administration ended with a continuing flurry of activity affecting U.S. sanctions and export controls, with several actions affecting parties in China and Hong Kong, the Biden Administration is taking a...more

BIS Rule Changes: The Gift That Keeps on Giving

As 2020 comes to a close, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) continues to implement new measures targeting countries of interest, among them Russia and China (which now, for export...more

Restrictions Affecting WeChat and TikTok: Now Clearly Defined, But Facing Legal Challenges

Just as quickly as the U.S. Department of Commerce announced the parameters of prohibitions on transactions involving TikTok and WeChat, pursuant to Executive Orders 13942 and 13943, respectively, actions were taken to delay...more

Commerce, State Departments Announce More Stringent Treatment of Exports to Hong Kong

On June 29, 2020, the US Secretary of State and the US Secretary of Commerce announced changes to US export controls in response to recent actions by China involving Hong Kong. These regulatory changes are likely not the last...more

BIS Targets Huawei with Expanded License Requirement for Foreign-Produced Direct Products

Effective May 15, 2020, the US Department of Commerce’s Bureau of Industry and Security (BIS) announced an interim final rule that introduces two new circumstances under the Export Administration Regulations (EAR) in which a...more

Exporting Under the EAR? Beware BIS Changes to Military End-Use/Military End-User Restrictions and License Exceptions

In a burst of activity, the US Department of Commerce, Bureau of Industry and Security (BIS) issued two final rules and one proposed rule. These rules, published in the Federal Register on April 28, 2020, made a series of...more

US Government Expands Restrictions on Huawei with New Entity List Designations, Issues Extension of Temporary General License

On August 19, 2019, the Department of Commerce, Bureau of Industry and Security (BIS) continued its actions restricting access by Huawei and certain of its non-US affiliates to goods, software and technology that are subject...more

Huawei Entities Added to US Entity List (IRB No. 578)

The Trump Administration announced last week that the US Government has added Huawei to the Commerce Department Entity List and, as of May 20, 2019, has announced a temporary general license for certain transactions. Here is...more

With the New Definitions Rules from Commerce and State, Do You Need to Change Your Export Compliance Program? (IRB No. 555)

The long-awaited definitions rules have finally arrived as part of Export Control Reform. But wait, they’re not all there—the definitions, that is. While Commerce addressed essentially all of the items included in its last...more

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