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After the fall of the former regime of Bashar al-Assad in Syria, the Presidential Administration has taken steps to formally dismantle the U.S.’s two-decade-long comprehensive trade restrictions on Syria. These steps began...more
On April 24, 2025, Ferroglobe USA, Inc. (“Ferroglobe”) and Mississippi Silicon LLC (Mississippi Silicon”) (collectively, “Petitioners”), filed a petition for the imposition of antidumping and countervailing duties on U.S....more
On January 20, 2025, within hours of taking the oath of office, President Trump signed an executive order (EO) entitled the America First Trade Policy. As anticipated, the EO directs the Department of Commerce, Department of...more
The Commerce Department issued new guidance for financial institutions on best practices for compliance with the Export Administration Regulations (EAR). Available here, the guidance emphasizes enhanced due diligence, ongoing...more
Teradyne, a Massachusetts-based supplier of semiconductor testing equipment, has reportedly pulled $1 billion of manufacturing equipment out of China in 2023 following export controls on advanced computing materials and...more
January saw continuing focus on Russia. First, the Commerce Department’s Bureau of Industry and Security (BIS) expanded export controls on certain goods for Russia and Belarus. Second, a U.S.-Israeli citizen was arrested for...more
December saw continuing enforcement actions involving Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC) settled investigations into apparent sanctions violations by a New York-based insurance...more
On 11/6/23, the Department of Commerce’s Bureau of Industry and Security (BIS) and FinCEN issued a joint notice regarding export control evasion highlighting a new Suspicious Activity Report key term (“FIN-2023-GLOBALEXPORT”)...more
As of Friday September 29, 2023, the United States Congress has yet to reach a spending agreement, as a result companies with international trade operations should prepare for a potential Federal government shutdown. The...more
On June 26, 2023, the Departments of Justice, Commerce, and Treasury issued a Tri-Seal Compliance Note that summarizes agency policy memoranda and existing regulations on voluntary self-disclosures (VSDs) of export controls...more
On July 26, 2023, the U.S. Department of Justice’s (DOJ’s) National Security Division (NSD), 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...more
On July 26, the Department of Commerce, Department of the Treasury, and Department of Justice released a Tri-Seal Compliance Note (July Note) providing guidance on voluntary self-disclosure of potential violations of U.S....more
On July 26, 2023, the Department of Justice (“DOJ”), the Department of Commerce’s Bureau of Industry and Security (“BIS”), and the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published their second...more
DOJ Increases Resources To Investigate and Prosecute Sanctions Evasion and Export Control Violations - On March 2, 2023, during a keynote speech at the American Bar Association’s annual White Collar Crime National...more