FCPA Compliance Report – Episode 732 – Understanding Anti-Boycott Compliance with Alexander Cotoia
ITAR for Facility Security Officers
ITAR for Government Contractors - New Developments for 2018
President Trump continued his flurry of sanctions actions with the recent revocation of the Syrian sanctions program. On June 30, 2025, President Donald Trump issued Executive Order (“EO”) 14312 “Providing for the Revocation...more
The Trump Administration is aiming to eliminate loopholes in the U.S. export controls system, expand the scope of the EAR, and ramp up enforcement. Get the insights you and your team need to strengthen your compliance program...more
On May 13, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) announced a recission of the Biden administration’s January 15, 2025 Artificial Intelligence Diffusion Interim Final Rule (“AI Diffusion...more
Between tariffs, tightening export controls, evolving sanctions, and ramped up enforcement, the cost and complexity of compliance is rising for oil and gas supply chains. ACI’s Trade & Sanctions Compliance for the Oil and...more
According to a trade press report, a Bureau of Industry and Security ("BIS"), Department of Commerce official speaking at the March 2025 BIS Update Conference on Export Controls and Policy recommended that U.S. exporters...more
As NATO procurement expands, Nordic companies must carefully navigate the intersection between NATO acquisition processes and multiple export control regimes, including those of the United States, the United Kingdom, and the...more
After three days of informational sessions on multiple regulatory and compliance topics, the Bureau of Industry and Security (“BIS”) wrapped up its annual update conference this week in Washington D.C. Secretary of Commerce...more
On 10/9/24, the Bureau of Industry and Security (BIS) within the Department of Commerce has issued guidance aimed at financial institutions (FIs), outlining best practices for adherence to the Export Administration...more
On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more
Pull quote: “Every export—every single one—has a related financial transaction” You are a banker. You do bankery things. You look at the ledgers, you tot up the numbers, you manage the accounts. Maybe you make loans,...more
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has published proposed amendments to the Export Administration Regulations (EAR) that would significantly expand the scope of the export controls over...more
The risks for international investments have sharply expanded in recent years. Identifying, managing, and mitigating investment risk, in the current regulatory environment, can be just as essential as managing risk in any...more
On July 29, the US government proposed big changes to rules about supporting or exporting to foreign military, intelligence, and security entities. The US Department of Commerce’s Bureau of Industry and Security (BIS) is...more
On July 10, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released new guidance (the “July 10 Release”) outlining different types of precautionary letters (“supplier list” letters, “Project...more
Implications Related to the Doubling of the Statute of Limitations for Civil and Criminal Violations of Two Primary Sanctions Authorities - SUMMARY - On April 24, 2024, President Biden signed into law a foreign military...more
Remarks given by Commerce Secretary Gina Raimondo and Undersecretary Alan Estevez during the 2024 Policy Update Conference sponsored by the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) emphasized the...more
The first quarter of 2024 saw numerous developments on the export control front. This report summarizes the key developments and provides links to the relevant Federal Register notices and/or agency announcements....more
The U.S. Government recently announced the largest round of sanctions against the Russian Federation (Russia) since the invasion of Ukraine two years ago. This multi-agency effort enacted over 500 sanctions against foreign...more
As discussed in our September 2023 Lawfare article, the Biden administration’s first-of-its-kind outbound investment review program seeks to limit outbound investments by U.S. investors in Chinese developers of certain...more
The Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued Joint Notice FIN-2023-NTC2, “Announnc[ing] New Reporting Key Term and...more
On May 19, 2023, the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced new export controls and Entity List additions during President Biden’s G7 visit in Japan. In conjunction with the G7 meetings,...more
As the European Union has made continued progress toward implementing a holistic human rights legislative agenda, the United States, in the wake of the recent second Summit for Democracy, began to push its own set of human...more
U.S. industries supplying Chinese facilities with products, equipment, software, and technology used in semiconductor development and production are subject to regulatory controls under the Export Administration Regulations...more
Most companies that employ non-U.S. persons in the United States are familiar with visa requirements, including completing U.S. Citizenship and Immigration Services Form I-129 – Petition for a Nonimmigrant Worker. However,...more
The Uyghur Forced Labor Protection Act (UFLPA) applies to all merchandise imported into the United States on or after June 22, 2022. The UFLPA establishes a rebuttable presumption that goods mined, produced, or manufactured...more