Many companies, particularly Software-as-a-Service (“SaaS”) and start-up companies, continue to struggle with the concept of export control classification of items with encryption functionality. This ongoing confusion is...more
On April 19, 2024, the Department of Commerce Bureau of Industry and Security (“BIS”) published an interim final rule (“Interim Rule”), amending the Export Administration Regulations (“EAR”) to enhance cooperation and...more
4/26/2024
/ Australia ,
Bureau of Industry and Security (BIS) ,
Comment Period ,
Export Administration Regulations (EAR) ,
Exports ,
Interim Rule ,
Licensing Rules ,
New Rules ,
Regulatory Agenda ,
Technology ,
UK
Those familiar with the U.S. import and export regulations know that U.S. Customs and Border Protection (“CBP” or “Customs”) generally enforces the U.S. import regulations, while multiple executive government agencies...more
1/2/2024
/ Asset Seizure ,
Bureau of Industry and Security (BIS) ,
Census Bureau ,
Customs and Border Protection ,
DEA ,
Directorate of Defense Trade Controls (DDTC) ,
Exports ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Requirements ,
Risk Assessment ,
Risk Management ,
U.S. Commerce Department
On October 17, 2023, the U.S. Department of Commerce Bureau of Industry & Security (“BIS”) released three rules amending the Export Administration Regulations (“EAR”) to strengthen export controls on advanced computing...more
11/1/2023
/ Bureau of Industry and Security (BIS) ,
China ,
ECCNs ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Final Rules ,
Licensing Rules ,
Manufacturers ,
Semiconductors ,
Technology Sector
In the nearly eighteen months since the Russian invasion of Ukraine, many companies have had to reanalyze their export control compliance procedures, particularly with respect to countries with adversarial or strained...more
9/1/2023
/ Bureau of Industry and Security (BIS) ,
Census ,
China ,
Electronic Export Information (EEI) ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Filing Requirements ,
Final Rules ,
Military End Use ,
Popular ,
Russia ,
Venezuela
As the war in Ukraine continues, the diversion of restricted goods and technology to Russia remains a risk for exporters. The Republic of Turkey has become a primary diversion point for such restricted goods. In the summer of...more
3/10/2023
/ Bureau of Industry and Security (BIS) ,
Customs and Border Protection ,
Directorate of Defense Trade Controls (DDTC) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Restricted Goods ,
Russia ,
Turkey ,
Ukraine
Compliance Program Guidelines -
On December 5, 2022, the U.S. Department of State Directorate of Defense Trade Controls (“DDTC”) issued new Compliance Program Guidelines (“the Guidelines”) intended to provide an overview...more
3/6/2023
/ Arms Export Control Act ,
Best Practices ,
Compliance ,
Directorate of Defense Trade Controls (DDTC) ,
Employee Training ,
Export Controls ,
Exports ,
ITAR ,
New Guidance ,
Policies and Procedures ,
Recordkeeping Requirements ,
Reporting Requirements ,
Risk Assessment ,
Risk Management