On 12 June 2024, the US Departments of Treasury, State, and Commerce imposed new restrictions targeting Russia, including: (i) restricting the provision of certain information technology and software services to Russia...more
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
October 2023 marked the first anniversary of the enhanced partnership between the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the United Kingdom Office of Financial Sanctions...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
On May 19, 2023, the US Department of Treasury, State, and Commerce imposed the most significant tranche of sanctions and export control measures in several months. The measures included (i) new designations on the Specially...more
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 United States government is increasingly scrutinizing U.S. industry’s reliance on China for biotechnology research and development and manufacturing, and is taking steps to expand export control requirements on China that...more
10/24/2022
/ Biotechnology ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Executive Orders ,
Export Control Reform Act (ECRA) ,
Export Controls ,
FIRRMA ,
National Security ,
Popular ,
Research and Development ,
Technology Sector
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
The U.S. Government has imposed additional punitive measures against Russia in response to Russia’s actions in Ukraine. The new measures include a prohibition on imports of Russian gold into the United States, new SDN and...more
7/5/2022
/ Blocking Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
FinCEN ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
State-Owned Enterprises ,
Supply Chain ,
Ukraine
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 Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) No. 22 on May 12, 2022, authorizing transactions that are ordinarily incident and necessary to activities that occur in specified, non-regime held...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 December 23, 2021, President Joe Biden signed into law the Uyghur Forced Labor Prevention Act (“UFLPA”). Most notably, the UFLPA strengthens the enforcement of Section 307 of the Tariff Act of 1930 by imposing a rebuttable...more
1/7/2022
/ Biden Administration ,
Child Labor ,
Corporate Social Responsibility ,
Customs and Border Protection ,
Export Controls ,
Forced Labor ,
Goods or Services ,
Human Rights ,
Imports ,
New Legislation ,
Office of Foreign Assets Control (OFAC) ,
Supply Chain
The release of data to a foreign person, even within U.S. borders, is deemed by U.S. export control laws to be an export to the recipient's country of permanent residency or citizenship. The delivery of U.S. export-controlled...more
The U.S. is one of the easiest jurisdictions in the world in which to do business1 . 1 Regulatory barriers are generally low, establishing a branch or business entity is quick and easy, labor and employment laws are much...more
On 24 September 2020, the U.S. Department of Treasury's Office of Foreign Asset Control (OFAC) announced a settlement with Keysight Technologies, Inc. (Keysight) for sanctions violations committed by its former subsidiary,...more
10/7/2020
/ Corruption ,
Country of Origin ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
General Licenses ,
Goods or Services ,
Iran Sanctions ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations
On Friday, May 22, 2020, the US Department of Commerce, Bureau of Industry and Security (BIS) announced in two separate press releases that it would be adding a number of companies and governmental entities to the Entity...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