On May 9, 2022, the Bureau of Industry and Security (“BIS”) released for public inspection a Final Rule adding hundreds of new items to a list of restricted items in Supplement No. 4 to Part 746 of the U.S. Export...more
This blog post covers several new sanctions and export controls that the U.S. government imposed on Russia and Belarus in the time period occurring between March 31, 2022 and April 21, 2022. ...more
4/25/2022
/ Bureau of Industry and Security (BIS) ,
CAPTA List ,
Commerce Control List ,
ECCNs ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Direct Product Rule ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Presidential Proclamations ,
Russia ,
SDN List ,
Trade Relations ,
U.S. Commerce Department ,
U.S. Treasury ,
Ukraine
On March 30, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) modified and expanded a list of aircraft that have flown into Russia in apparent violation of the Export Administration Regulations...more
On March 24, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) updated the Specially Designated Nationals and Blocked Persons List (“SDN List”) with hundreds of new designations pursuant to...more
On March 18, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) publicly identified certain commercial and private aircraft that have entered Russia in likely violation of the Export...more
On Friday, March 11, 2022, the White House issued Executive Order (“EO”) 14068 announcing more sanctions and export controls against the Russian Federation (“Russia”). Concurrent with that announcement, the U.S....more
On March 8, 2022, President Biden issued Executive Order 14066 which prohibits the following actions:
The importation into the United States of any “crude oil; petroleum; petroleum fuels, oils, and products of their...more
On February 24, 2022, the U.S. imposed sweeping sanctions and export controls actions in response to the Russian Federation’s (“Russia”) “war of choice” against Ukraine. ...more
3/8/2022
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
European Central Bank ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
General Licenses ,
Joe Biden ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
SWIFT ,
U.S. Commerce Department ,
U.S. Treasury ,
Ukraine
Key point: On February 24, 2022, the United States imposed a combination of extensive and complex trade sanctions and export controls against the Russian Federation (Russia) in response to its invasion of Ukraine. These...more
2/28/2022
/ Bureau of Industry and Security (BIS) ,
CAPTA List ,
Commerce Control List ,
ECCNs ,
Economic Sanctions ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
Ukraine
On February 22, 2022, one day after the Russian Federation formally recognized the Donetsk People’s Republic (“DNR”) and Luhansk People’s Republic (“LNR”) of Ukraine as “independent states” and the Biden Administration...more
2/23/2022
/ Banks ,
CBW Act ,
Economic Sanctions ,
Energy Sector ,
Export Administration Regulations (EAR) ,
Financial Services Industry ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
SSI List ,
U.S. Commerce Department ,
U.S. Treasury ,
Ukraine
On February 21, 2022, U.S. President Joseph R. Biden Jr. issued an Executive Order (the “Ukraine Order”) in response to action taken earlier in the day by Russian Federation President Vladimir Putin to recognize the Donetsk...more
Effective January 13, 2022, the U.S. Census Bureau’s (“Census”) Automated Export System (“AES”) began issuing a response code 66Q notifying Electronic Export Information (“EEI”) filers whenever they enter an export control...more
Russia has amassed more than 100,000 troops at the Ukrainian border, leading the White House to issue a warning on January 25 that the U.S. is “prepared to implement sanctions with massive consequences that were not...more
2/2/2022
/ Bureau of Industry and Security (BIS) ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Joe Biden ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
SDN List ,
SWIFT ,
Ukraine
As tensions run high between Washington and Moscow over a possibly imminent Russian invasion of Ukraine, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated today four (4) current and...more
In an October 21, 2021 interim final rule (“IFR”), the Bureau of Industry and Security (“BIS”) published long-awaited “cybersecurity items” controls in Categories 4 (Computers) and 5, Pt. 1 (Telecommunications) of the...more
1/21/2022
/ Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Cybersecurity ,
ECCNs ,
Export Administration Regulations (EAR) ,
Interim Final Rules (IFR) ,
ITAR ,
National Security ,
Popular ,
Software ,
Surveillance
Husch Blackwell’s third-annual international trade law year-in-review report provides a detailed look at how 2021 played out and takes a peek at how 2022 might develop. As companies begin to strategize on what a second year...more
1/4/2022
/ Anti-Dumping Duty ,
China ,
Countervailing Duties ,
Court of International Trade ,
Customs and Border Protection ,
Digital Currency ,
Export Controls ,
False Claims Act (FCA) ,
Free Trade Agreements ,
Imports ,
International Trade ,
NAFTA ,
Office of Foreign Assets Control (OFAC) ,
Patent Trial and Appeal Board ,
Section 301 ,
Supply Chain ,
Tariffs ,
Trade Policy ,
Trade Promotion Authority ,
United States-Mexico-Canada Agreement (USMCA) ,
US-China Economic and Security Review Commission (USCC)
On October 5, 2021, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule in the Federal Register that places new controls on software and technology that can potentially be used for...more
The Department of Commerce’s (“Commerce”) Bureau of Industry & Security (“BIS”) recently issued requests for comment on risks to the information communications and technology (“ICT”) and semiconductor supply chains...more
During the past month, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) has issued three separate rounds of Specially Designated Nationals & Blocked Persons List (“SDN List”) designations in order...more
On August 9, 2021, President Biden issued Executive Order 14038 (the “EO”) which expanded the scope of the national emergency previously declared in EO 13405 of June 16, 2006. The EO imposes additional sanctions in response...more
Effective July 2, 2021, as part of the U.S. Government’s ongoing response to the military coup in Burma (Myanmar), the Department of Commerce’s Bureau of Industry and Security (“BIS”) added four entities to the Entity List...more
Earlier this month, the US Government updated its ongoing response to what the Department of Commerce (“Commerce”) described as “Beijing’s campaign of repression, mass detention, and high-technology surveillance against...more
7/23/2021
/ Anti-Money Laundering ,
Bureau of Industry and Security (BIS) ,
China ,
Department of Homeland Security (DHS) ,
Export Administration Regulations (EAR) ,
Military End Use ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
SDN List ,
Surveillance ,
U.S. Commerce Department ,
USTR
The Biden Administration has taken new actions related to forced labor in the Xinjiang region that may affect the supply for material critical for solar panels: U.S. Customs and Border Protection (CBP) issued a Withhold...more
On January 23, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and the U.S. Department of State issued two final rules, available here and here. The final rules outlined the removal of...more
6/9/2021
/ 3D Printing ,
Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Export Administration Regulations (EAR) ,
Exports ,
Federal Register ,
Firearms ,
ITAR ,
Software ,
Technology Sector ,
U.S. Commerce Department ,
US Department of State
Recently, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) sanctioned various individuals and entities connected to Russia’s technology sector and also expanded sanctions against dealings in Russian...more
4/21/2021
/ Biden Administration ,
Cyber Attacks ,
Cyber Crimes ,
Defense Sector ,
Election Interference ,
Executive Orders ,
Export Controls ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanctions ,
SDN List ,
Sovereign Debt ,
State-Owned Enterprises ,
Technology Sector ,
U.S. Treasury