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U.S. Agencies Caution Foreign-Based Persons on Extraterritorial Reach of U.S. Sanctions and Export Control Regulations

On March 6, 2024, the U.S. Departments of the Treasury, Commerce, and Justice jointly issued a Tri-Seal Compliance Note titled “Obligations of Foreign-Based Persons to Comply with U.S. Sanctions and Export Control Laws”...more

New Commerce Rule Covering ICTS Transactions Involving Foreign Parties

A new rule effective March 22, 2021 establishes a process for the US Department of Commerce to review commercial transactions between US and foreign parties for certain information and communications technology and services...more

New Rule Expands US Government Contracting Ban on Targeted Chinese Telecommunications

Beginning on August 13, U.S. federal government agencies will be prohibited from issuing new contracts or extending or renewing existing contracts to entities that use certain telecommunications and video surveillance...more

New Commerce Department FAQs Require Due Diligence by Exporters to Assess Chinese Military End Uses and Users

On June 29, 2020, the Commerce Department issued 32 Frequently Asked Questions (FAQs) concerning revision - effective as of the same date - to Part 744.21 of the Export Administration Regulations (EAR). As we discussed in a...more

Commerce Department Escalates US-China Technology Competition, Targeting Huawei Again

On May 15, 2020, the US Department of Commerce announced a rule further targeting Chinese telecommunications company Huawei and its chip-making subsidiary HiSilicon for allegedly engaging in “stepped-up efforts to undermine”...more

New Commerce Department Rules Restrict US Exports to China and Other Countries

Yesterday, the US Department of Commerce Bureau of Industry and Security (BIS) promulgated two new rules and issued a new proposed rule: ..A new final rule that will restrict previously permissible exports to China, Russia...more

Commerce Department Proposes Rule to Review Broad Range of ICTS Transactions

On November 26, the US Department of Commerce issued a long-awaited proposed rule (Proposed Rule) implementing new restrictions designed to protect the US information and communications technology and services (ICTS) supply...more

The U.S. Administration Targets Huawei in Actions to Curtail its Involvement in U.S. Telecommunications Networks and Access to...

On May 15, 2019, President Trump issued an Executive Order (EO) declaring a national emergency and paving the way for a ban on the use of Huawei equipment and services in U.S. telecommunication networks. On the same day, the...more

Department of Commerce Now Accepting Privacy Shield Self-Certifications: A Primer for Compliance and Self-Certification

The Privacy Shield framework is a voluntary program that provides companies with a mechanism for complying with EU data protection requirements when transferring personal data from the EU to the US. The framework is open to...more

Privacy Shield Moves Forward, Company Certifications to Begin August 1

The European Commission formally adopted the EU-US Privacy Shield on July 12, 2016, ending months of legal uncertainty with a new framework for governing transatlantic data transfers after the Privacy Safe Harbor framework...more

European Commission and U.S. Department of Commerce Release Legal Foundation of EU-U.S. Privacy Shield

On Monday, February 29th, the European Commission and U.S. Department of Commerce released a collection of documents summarizing actions taken on both sides of the Atlantic to implement the new Privacy Shield framework. This...more

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