On April 29, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule to add a new license exception for medical devices (License Exception MED) to authorize the export, reexport, and...more
Following the death of political activist Aleksey Navalny and to mark the second anniversary of Russia’s invasion of Ukraine, the United States, EU and UK adopted a series of amendments to their respective economic sanctions...more
On December 8, 2023, the Bureau of Industry and Security (BIS) issued three separate rules to amend the Export Administration Regulations (EAR) to liberalize several categories of export licensing requirements and make...more
The Department of Commerce’s Bureau of Industry and Security issued two interim final rules to expand on the 7 October 2022 restrictions aimed at denying access to certain advanced semiconductors, semiconductor manufacturing...more
The U.S. Departments of Commerce, Justice and Treasury have issued a “Tri-Seal” Compliance Note regarding national security laws and regulations and the voluntary self-disclosure of potential violations, highlighting...more
8/2/2023
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Export Administration Regulations (EAR) ,
Export Controls ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
U.S. Treasury ,
Voluntary Disclosure
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) clarified its policy regarding voluntary self-disclosures and enforcement actions on April 18, 2023. Historically, a failure to voluntarily...more
In 2021, the Export Controls and Human Rights Initiative (“ECHRI”) was launched at the first Summit for Democracy as part of the Presidential Initiative for Democratic Renewal. This year, during the Summit for Democracy 2023...more
On February 16, 2023, the Department of Justice (DOJ) and the Department of Commerce (Commerce) announced the creation of a joint Disruptive Technology Strike Force (Strike Force). The Strike Force will be co-led by the...more
3/7/2023
/ Bureau of Industry and Security (BIS) ,
CFIUS ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Technology Sector ,
U.S. Commerce Department
Through Aerospace & Defense Insights, we share with you the top legal and political issues affecting the aerospace and defense (A&D) industry. Our A&D industry team monitors the latest developments to help our clients stay in...more
The United States Department of Commerce’s Bureau of Industry and Security has issued regulations to amend the Export Administration Regulations to implement changes to controls of certain viruses, marine toxins, plant...more
The Department of Commerce’s Bureau of Industry and Security has issued an interim final rule to deny China’s access to certain semiconductor and advanced computing technology and to inhibit China’s ability to manufacture...more
On 2 June 2022, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) issued two final rules, effective on the same day, that revised the Export Administration Regulations (“EAR”) pertaining to the U.S.’s...more
The U.S. Bureau of Industry and Security (“BIS”) has expanded export controls relating to Russia. The final rule imposes license requirements for exports, reexports and transfers to/within Russia on several items with...more
On February 24, 2022, the US Government imposed severe economic sanctions and export controls on Russia. The restrictions consist of two parts: 1) significant financial sanctions on a range of Russian financial institutions...more
On February 8, 2022, the Bureau of Industry and Security (“BIS”) published a Final Rule amending the Export Administration Regulations (“EAR”) to add 33 persons to the Unverified List (“UVL”) pursuant to § 744.15(c) of the...more
On November 26, 2021, the Bureau of Industry and Security (BIS) published a Final Rule adding 27 entities to the Entity List under the Export Administration Regulations (EAR). These entities are located in China, Japan,...more
The U.S. Commerce Department’s Bureau of Industry and Security has added seven Chinese entities to the Entity List. This rule is effective 8 April 2021. On 8 April 2021, the U.S. Commerce Department’s Bureau of Industry and...more
On 15 January 2021, the Bureau of Industry and Security (BIS) published an interim final rule imposing new restrictions requiring licenses for transactions involving exports, reexports, or transfers, as well as certain...more
The Commerce Department’s Bureau of Industry and Security has announced an Interim Final Rule amending the Export Administration Regulation’s General Prohibition Three, the foreign-produced direct product rule....more
5/18/2020
/ Bureau of Industry and Security (BIS) ,
China ,
Comment Period ,
Commerce Control List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
Huawei ,
Prohibited Transactions ,
Supply Chain ,
Telecommunications ,
U.S. Commerce Department
On 28 April the U.S. Commerce Department, Bureau of Industry and Security published two final rules and a proposed rule amending the Export Administration Regulations that will further restrict and regulate transactions...more
As of 16 March 2020 Iran Air and a number of other entities were placed on the Bureau of Industry and Security's (BIS) Entity List.
Summary -
Companies that use Iran Air as transport, particularly companies engaging in...more
3/17/2020
/ Airlines ,
Aviation Industry ,
Bureau of Industry and Security (BIS) ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
General Licenses ,
Iran ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions
On 24 February 2020 the Bureau of Industry and Security (BIS) of the U.S. Department of Commerce published a final rule amending the Export Administration Regulations (EAR) and imposing additional export licensing...more
2/28/2020
/ Aircraft ,
Biological-Weapons ,
Bureau of Industry and Security (BIS) ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Relations ,
Licensing Rules ,
National Security ,
Nuclear Weapons ,
Russia ,
Software ,
U.S. Commerce Department ,
Vessels ,
Yemen
The U.S. Department of Commerce's Bureau of Industry and Security (BIS) published an interim final rule on 6 January 2020 imposing licensing requirements on certain artificial intelligence software specially designed to...more
1/30/2020
/ Bureau of Industry and Security (BIS) ,
ECCNs ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Final Rules ,
Interim Final Rules (IFR) ,
Popular ,
Rulemaking Process ,
Software ,
U.S. Commerce Department
Two years after the release of the first draft of the Chinese Export Control Law (the Law) in 2017 (the 2017 Draft), on 28 December 2019, a revised draft was published on the website of the National People's Congress for...more
1/8/2020
/ China ,
De Minimus Quantity Exemption ,
Dual Use Goods ,
End-Users ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Licensing Rules ,
Military End Use ,
Military Goods ,
Policies and Procedures ,
Trade Policy ,
Use in Commerce
On 21 October 2019 the Bureau of Industry and Security (BIS) issued a final rule amending Cuba-related provisions in the Export Administration Regulations (EAR).
The new rule further restricts exports and reexports of...more
10/25/2019
/ Aerospace ,
Aircraft Sales ,
Airlines ,
Bureau of Industry and Security (BIS) ,
Cuba ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Infrastructure ,
Licensing Rules ,
Revenue ,
Sanctions ,
Telecommunications ,
Threshold Requirements ,
Trade Relations ,
Vessels