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Trump Administration’s First Export Control Action – Reading the Tea Leaves

On March 25, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a significant expansion of its Entity List restrictions, adding 80 entities from China, the United Arab Emirates, South Africa,...more

BIS Strengthens Export Controls on ‎China’s Advanced Technology Capabilities

On December 2, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced two interim final rules (collectively, the “December 2024 Rules”) (“Foreign-Produced Direct Product Rule Additions, and...more

BIS Issues New Guidance to Financial ‎Institutions on Best ‎Practices for Compliance With ‎the EAR

On October 9, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued its first-ever guidance to financial institutions (“FIs”) on best practices to comply with the Export Administration...more

Key Takeaways for Antiboycott Compliance Programs Following BIS Penalizing Company for Antiboycott Violations

On September 30, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a civil penalty of $151,875 against a U.S.-based technology company to resolve 45 alleged violations of the antiboycott...more

OFAC Issues Global Magnitsky ‎Sanctions Relief for Ly Young Phat Group and FAQs

On September 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 8 alongside amendments to various Frequently Asked Questions (“FAQs”) in connection with the...more

Guidelines for Preparing BIS Export ‎License Applications Involving Foreign Persons ‎‎(Deemed ‎Exports-Reexports)‎

On September 1, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released new guidelines to support deemed export applicants in acquiring necessary licenses. While these guidelines are primarily...more

BIS Proposes New Reporting ‎Requirements for the Development ‎of Advanced AI Models & ‎Computing Clusters

On September 9, 2024, U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a Notice of Proposed Rule Making (“NRPM”), which would mandate new reporting requirements for artificial intelligence (“AI”)...more

BIS Issues Key Updates to the ‎Voluntary Self-Disclosure Process ‎and Penalty Guidelines

On September 12, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule that requires reporting entities to make significant changes to Voluntary Self-Disclosures (“VSD”); the BIS...more

BIS Issues Export Guidance to ‎Academia

On August 14, 2024, the U.S. Department of Commerce's Bureau of Industry and Security (“BIS”) issued guidance to the U.S. academic community regarding compliance with export controls and to protect U.S. national security....more

U.S. Anti-Boycott Pitfalls

In a recent enforcement action, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a civil penalty on a U.S. company for violations of the antiboycott provisions under Part 760 of the Export...more

BIS Issues New FDP Restrictions on Goods Destined for Iran

On April 24, 2024, President Biden signed into law the "Making Emergency Supplemental Appropriations for the Fiscal Year Ending September 30, 2024, and for Other Purposes" Act. This law mandates that the United States...more

BIS Tightens Export Controls on Russia ‎and Belarus

On August 23, 2024, the U.S. Department of Commerce's Bureau of Industry and Security (“BIS”) announced a series of new measures to further restrict the supply of U.S.-origin and "U.S.-branded" items to Russia and Belarus...more

BIS Releases Updated “Don’t Let This Happen to You!” Guidance

On July 1, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released an updated version of Don’t Let This Happen To You!, which contains summaries of actual investigations of Export Control and...more

BIS Announces Additional Export ‎Control Restrictions Against ‎Russia and Belarus Targeting Shell ‎Companies and Business...

Effective as of June 12, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced several additional export control restrictions and related actions against Russia and Belarus to further...more

OFAC Limits Exports of Technology to Russia ‎‎‎and Expands Secondary Sanctions on FFIs That Support ‎Russian War ‎Efforts

On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a new Determination Pursuant to Section 1 (a)(ii) of Executive Order 14071 (the “Determination”)‎ that prohibits U.S....more

BIS Introduces License Exception MED ‎for Medical Device ‎Exports to Russia, Belarus, and Occupied ‎Ukraine

Effective April 29, 2024, the U.S. Department of Commerce's Bureau of Industry and Security (“BIS”) introduced a new export license exception to allow the export of medical devices to or within Russia, Belarus and the...more

U.S. Commerce Department ‎Coordinates Efforts With OFAC to Counter National Security ‎Threats

The U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) introduced a significant final rule on March 20, 2024, intending to fortify national security. This rule amendment enhances restrictions under the Export...more

Department of Commerce Launches ‎Public List to Aid Compliance With Antiboycott Regulations

The Office of Antiboycott Compliance (“OAC”) within the U.S. Department of the Treasury’s Bureau of Industry and Security (“BIS”) is charged with administering and enforcing the Anti-Boycott Act of 2018, Part II of the Export...more

BIS Penalizes U.S. Corporation for Anti-‎Boycott Violations

On January 29, 2024, the Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a civil penalty of $153,175 against a global rail technology manufacturer headquartered in Pittsburgh, Pennsylvania (the...more

BIS Issues Three New Rules to Ease ‎Licensing Requirements and ‎Enhance Exceptions for Exports to ‎Selected Countries

On December 6, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) unveiled three pivotal rules that amend the Export Administration Regulations (“EAR”). These rules mark a crucial step in a...more

FinCEN Report Identifies Potential ‎Evasion of US Export Controls; The U.S. ‎FDPR and End Use ‎End User Certificate Protections

On September 8, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) released its Financial Trend Analysis (“FTA”). The FTA details FinCEN’s analysis of suspicious activity reports...more

Joint Compliance Note Issued by ‎Departments of Justice, ‎Commerce and Treasury on Voluntary ‎‎Self-Disclosure of ‎Potential...

On July 26, 2023, the U.S. Department of Justice (“DOJ”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a...more

OFAC Russia Related Sanctions Update: ‎June 2023‎

On May 19, 2023, the U.S. Department of Commerce Bureau of Industry and Security (“BIS”) issued additional export control restrictions aimed at further degrading the Russian Federation’s capacity to wage its aggression...more

OFAC Russia Related Sanctions Update: ‎April 2023‎ #2

On April 12, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published four new General Licenses (“GL”) (GL 62, GL 63, GL 64, and GL 65), revoked GL 15, and issued FAQ 1122 related to the...more

Iran Related Sanctions and Export ‎Controls Update: March 2023‎

On February 27, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Iran Final Rule”) imposing new export control measures against Iran caused by to its support of Russian...more

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