On August 9, 2023, the President issued a widely anticipated executive order ("EO") establishing the framework for a U.S. outbound investment program to address threats to U.S. national security created by certain...more
8/15/2023
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Artificial Intelligence ,
Biden Administration ,
China ,
Executive Orders ,
Foreign Investment ,
National Security ,
NDAA ,
Outbound Transactions ,
Public Comment ,
Supply Chain
Current as of June 29, 2023 -
This update discusses the May 19, 2023 and subsequent actions taken by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) in response to the continued aggression of...more
6/30/2023
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
General Licenses ,
Magnitsky Act ,
Military Conflict ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
UK ,
Ukraine
On May 19, the Bureau of Industry and Security (BIS) issued two final rules expanding the export controls in the Export Administration Regulations (EAR) against the Russian Federation (Russia) for its continued war with...more
6/27/2023
/ Belarus ,
Blocked Person ,
Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Directorate of Defense Trade Controls (DDTC) ,
Economic Sanctions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Direct Product Rule ,
General Licenses ,
ITAR ,
Military End Use ,
Russia ,
U.S. Commerce Department
Recent acquisitions of land by foreign buyers have sparked concern that the current jurisdiction of the Committee on Foreign Investment in the United States (CFIUS) to review such transactions is not broad enough. CFIUS,...more
5/18/2023
/ Agricultural Sector ,
CFIUS ,
FIRRMA ,
Foreign Acquisitions ,
Foreign Investment ,
Foreign Nationals ,
Government Property ,
Jurisdiction ,
National Guard ,
National Security ,
Proposed Legislation ,
Proposed Rules ,
Real Estate Transactions ,
US Air Force ,
USDA
On Feb. 24, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued a final rule amending the Commerce Control List (CCL) in part 774 of the Export Administration Regulations (EAR) to complete...more
The U.S. government recently has taken several actions targeting Iran and Iranian entities for contributing to Russia’s military and defense industrial base to address Russia’s use of Iranian unmanned aerial vehicles (UAVs)...more
3/28/2023
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Indictments ,
Iran ,
Iran Sanctions ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine ,
Unmanned Aircraft Systems
On Feb. 24, 2023, the first anniversary of Russia’s invasion of Ukraine, the Bureau of Industry and Security (BIS) imposed further export controls on Russia and Belarus by expanding the scope of EAR99 items, including luxury...more
3/24/2023
/ Belarus ,
Belarus Sanctions ,
Bureau of Industry and Security (BIS) ,
Commerce Control List ,
ECCNs ,
Economic Sanctions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
General Licenses ,
Russia ,
Ukraine
This update outlines the actions taken by U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) on Feb. 24, 2023, the one-year anniversary of the invasion of Ukraine by the Russian Federation (Russia)....more
3/14/2023
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Country of Origin ,
Economic Sanctions ,
Export Controls ,
Foreign Policy ,
Military Conflict ,
Mining ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Russia ,
Ukraine
Seeking to protect critical U.S. technological assets from being acquired or used by nation-state adversaries, last week Deputy Attorney General Lisa Monaco announced the launch of the Disruptive Technology Strike Force....more
This update addresses the full implementation of the price cap policy for crude oil and petroleum products of Russian origin by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). On Feb. 3, OFAC...more
2/21/2023
/ Biden Administration ,
Blocked Person ,
Bureau of Industry and Security (BIS) ,
Crude Oil ,
Economic Sanctions ,
Embargo ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
G7 ,
General Licenses ,
Infrastructure ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Petroleum ,
Pipelines ,
Popular ,
Russia ,
SDN List ,
SWIFT ,
Ukraine
This update addresses the full implementation of the price cap policy for crude oil and petroleum products of Russian origin by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). On Feb. 3, OFAC...more
2/17/2023
/ Blocked Person ,
CAATSA ,
Crude Oil ,
Economic Sanctions ,
Executive Orders ,
Exports ,
General Licenses ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Popular ,
Russia ,
Ukraine
The U.S. government’s most comprehensive survey regarding foreign direct investment in the United States is being conducted in 2023. The survey is the BE-12, a five (5) year benchmark survey conducted by the U.S. Department...more
UPDATE – December 2022 was another busy month for Entity List additions by BIS.
Effective Dec. 21, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) further tightened controls on the Wagner...more
1/19/2023
/ Belarus ,
Blocked Entities ,
Blocked Person ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
General Licenses ,
Military Conflict ,
Military End Use ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine
This update includes the U.S. Department of the Treasury’s Office of Foreign Assets Control’s (OFAC) recent actions regarding the Russian seaborne oil price cap policy aimed at maintaining the supply of Russian oil to the...more
1/11/2023
/ Belarus ,
Belarus Sanctions ,
Bureau of Industry and Security (BIS) ,
Crude Oil ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Popular ,
Russia ,
SDN List ,
Ukraine ,
US Department of State
Key Takeaways -
..New export controls are in place that impose significant new restrictions for U.S. and foreign businesses operating in the semiconductor and advanced computing industry in China.
..The new controls...more
11/17/2022
/ Bureau of Industry and Security (BIS) ,
China ,
Comment Period ,
Commerce Control List ,
ECCNs ,
End-Users ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Direct Product Rule ,
Interim Final Rules (IFR) ,
New Regulations ,
Popular ,
Semiconductors ,
Technology Sector
In response to the Russian Federation’s (Russia) egregious and unprovoked invasion of Ukraine that began in February 2022, the U.S. government has deployed a whole-of-government approach in imposing sanctions and export...more
10/26/2022
/ Biden Administration ,
Blocked Person ,
Blocking Sanctions ,
CAATSA ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
General Licenses ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
Trade Restrictions ,
Ukraine
UPDATE – Effective September 15, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) implemented a new rule that expanded, revised, corrected and clarified certain provisions of the Export...more
10/25/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Directorate of Defense Trade Controls (DDTC) ,
ECCNs ,
Economic Sanctions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Licensing Rules ,
Military End Use ,
New Rules ,
Russia ,
Tariffs ,
U.S. Commerce Department
The U.S. Department of the Treasury on October 20, 2022, issued its first-ever Committee on Foreign Investment in the United States (CFIUS) Enforcement and Penalty Guidelines. Publishing of the Guidelines reinforces recent...more
Key Takeaways -
..The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is prohibiting the provision of accounting, trust and corporate formation, and management services to any person in the...more
7/19/2022
/ Biden Administration ,
Blocked Entities ,
Blocked Person ,
Consultants ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
Franchise Taxes ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Service Contracts
On June 29, 2022 through July 1, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) held its 35th Annual Update Conference on Export Controls and Policy (Update) in Washington, D.C. This important...more
7/11/2022
/ Bureau of Industry and Security (BIS) ,
China ,
Compliance ,
Directorate of Defense Trade Controls (DDTC) ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
General Licenses ,
ITAR ,
National Intelligence Agencies ,
National Security ,
Russia ,
U.S. Commerce Department
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
5/20/2022
/ Belarus ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Directorate of Defense Trade Controls (DDTC) ,
Entity List ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
General Licenses ,
Military End Use ,
Prohibited Transactions ,
Russia ,
SDN List ,
Trade Restrictions ,
Ukraine
On March 15, 2022, the United States added additional Russian and Belarusian individuals and one Russian entity to the Department of the Treasury’s Office of Foreign Assets Control (OFAC) list of Specially Designated...more
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
3/14/2022
/ Biden Administration ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
G7 ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine
President Biden signed an Executive Order prohibiting the importation into the United States of Russian origin crude oil, petroleum, petroleum fuels, oils, and products of their distillation; liquefied natural gas (LNG);...more
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
3/7/2022
/ Asset Seizure ,
Biden Administration ,
Blocked Entities ,
Blocked Person ,
Bureau of Industry and Security (BIS) ,
Defense Sector ,
Department of Justice (DOJ) ,
ECCNs ,
Economic Sanctions ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Financial Institutions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
Technology Sector ,
UK ,
Ukraine