On 19 September 2020, China's Ministry of Commerce (MOFCOM) published the Provisions on the Unreliable Entity List (Order No.4 of 2020) (provisions), which immediately came into effect. It has been over one year since MOFCOM...more
The Cuban Assets Control Regulations have been amended to prohibit U.S. persons from lodging at certain properties in Cuba, incorporate restrictions on imports of Cuban alcohol and tobacco, and revoke general licenses...more
On 14 July, the same day the president signed into law the Hong Kong Autonomy Act (the act), President Trump issued the Executive Order on Hong Kong Normalization (the EO) directing federal agencies to impose a range of trade...more
On June 28, 2010, the Standing Committee of China's National People's Congress (NPC) reviewed the second draft of China's Export Control Law (the "Law"). Six months had passed since the Law was first reviewed by the NPC in...more
On 29 June 2020, the final rule expanding the military end user/user controls (MEU) issued by the Bureau of Industry and Security (BIS) went into effect. On 26 June 2020, BIS issued an FAQs guidance document that provides...more
On 22 June President Trump signed the Proclamation Suspending Entry of Aliens Who Present a Risk to the U.S. Labor Market Following the Coronavirus Outbreak. This executive action extends the president's April 2020 suspension...more
6/28/2020
/ Coronavirus/COVID-19 ,
Foreign Nationals ,
Foreign Workers ,
H-1B ,
H-2B ,
Immigration Procedures ,
J-1 Visas ,
L-1 Visas ,
Non-Immigrant Visas ,
Presidential Proclamations ,
Trump Administration ,
Visas
On 24 June 2020, the United States Department of Defense made public a list of Chinese companies operating in the U.S. that are associated with the Chinese military. ...more
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
On 27 May 2020 U.S. Secretary of State Pompeo certified to Congress that the State Department no longer considers Hong Kong to have significant autonomy from China and therefore "Hong Kong does not continue to warrant...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
The EU has imposed restrictions on exports of certain personal protective equipment (PPE), whether originating or not in the European Union, in response to the COVID-19 outbreak....more
On 27 February 2020, the Office of Foreign Assets Controls (OFAC) issued General License (GL) 8 authorizing certain humanitarian trade transactions involving the Central Bank of Iran (CBI) that are otherwise prohibited under...more
3/6/2020
/ Banks ,
Commodities ,
Economic Sanctions ,
Food Supply ,
Foreign Relations ,
General Licenses ,
Global Terrorism Sanctions Regulations (GTSR) ,
Humanitarian Assistance ,
Iran ,
Iran Sanctions ,
ITSR ,
Medical Devices ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Requirements ,
Reporting Requirements ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Switzerland ,
Trade Agreements
A deeper dive into the president's FY2021 budget request for the U.S. Department of Commerce reveals new initiatives aimed at safeguarding technology.
- The National Telecommunications and Information Administration (NTIA)...more
2/28/2020
/ 5G Network ,
Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
China ,
Critical Infrastructure Sectors ,
Emerging Technologies ,
Export Controls ,
NIST ,
NTIA ,
Supply Chain ,
Telecommunications ,
Trump Administration ,
U.S. Commerce Department
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
On 6 January 2020, the State Department's Directorate of Defense Trade Controls (DDTC) issued new frequently asked questions (FAQs) regarding the registration and licensing requirements under the International Traffic in Arms...more
On 10 January 2020, in response to missile attacks by the Iranian military targeting two U.S. bases in Iraq, the United States Department of the Treasury, Office of Foreign Assets Control (OFAC) designated a number of senior...more
1/14/2020
/ Blocked Person ,
Construction Project ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Goods or Services ,
Iran ,
Iran Sanctions ,
Manufacturers ,
Mining ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
SDN List ,
Textiles ,
Trump Administration
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 13 December 2019 the U.S. Department of Justice's (DOJ) National Security Division (NSD) announced the release of its long-anticipated and updated Export Control and Sanction Enforcement Policy for Business Organizations...more
12/19/2019
/ Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Authority ,
Export Controls ,
FCPA Guidance ,
National Security ,
Policy Statement ,
Sanction Violations ,
Self-Reporting ,
Trade Relations ,
Willful Misconduct
The Committee on Foreign Investment in the United States (CFIUS or the committee), a U.S. government interagency committee that conducts national security reviews of foreign investments, has released its annual report for...more
On 26 November 2019 the U.S. Department of Commerce issued a long-awaited proposed rule (or draft regulations) to implement Executive Order 13873, "Securing the Information and Communications Technology and Services Supply...more
11/27/2019
/ Acquisitions ,
Critical Infrastructure Sectors ,
Foreign Adversaries ,
Imports ,
Proposed Rules ,
Risk Assessment ,
Risk Management ,
Secretary of Commerce ,
Supply Chain ,
Telecommunications ,
Trump Administration ,
U.S. Commerce Department
On 5 November 2019 the Office of Foreign Assets Control (OFAC) issued two new general licenses authorizing certain transactions involving the government of Venezuela (GOV) and certain individuals affiliated with the GOV,...more
On 25 October the U.S. Departments of the Treasury and State announced the establishment of a new channel for conducting due diligence on humanitarian trade with Iran.
Foreign governments and foreign financial institutions...more
11/8/2019
/ AML/CFT ,
Due Diligence ,
FinCEN ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Humanitarian Assistance ,
Iran ,
Iran Sanctions ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Trump Administration