Welcome to the April 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more
4/11/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Country of Origin ,
Customs and Border Protection ,
Economic Sanctions ,
Enforcement Actions ,
Executive Orders ,
Export Controls ,
False Claims Act (FCA) ,
Forced Labor ,
Harmonized Tariff Schedule of the United States (HTSUS) ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Supply Chain ,
Tariffs ,
Trade Wars ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
President Trump’s first months in office have been busy, but, in the export control world, we have been grateful for a brief respite from the mind-bending, hundreds-of-pages-long, industry-changing rules that the US...more
The US Department of Commerce’s Bureau of Industry and Security (BIS) introduced its long-anticipated (some would say dreaded) Framework for Artificial Intelligence Diffusion (the AI Diffusion Rule) on January 15. Highlights...more
1/17/2025
/ America Invents Act ,
Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Department of Energy (DOE) ,
Export Administration Regulations (EAR) ,
Export Controls ,
Final Rules ,
Foreign Direct Product Rule ,
Innovative Technology ,
Interim Final Rules (IFR) ,
National Security ,
Semiconductors ,
Technology Sector
Welcome to the October 2024 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more
10/18/2024
/ Aluminum Sales ,
Automotive Industry ,
Bureau of Industry and Security (BIS) ,
China ,
Compliance ,
E-Commerce ,
Fashion Industry ,
Forced Labor ,
Foreign Trade Zones ,
Importers ,
Manufacturers ,
NAFTA ,
Proposed Rules ,
Retailers ,
Russia ,
Supply Chain ,
Technology Sector ,
Trade Act of 1974 ,
Trade Relations ,
U.S. Customs ,
United States-Mexico-Canada Agreement (USMCA) ,
USTR ,
Uyghur Forced Labor Prevention Act (UFLPA)
Welcome to the September 2024 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more
9/17/2024
/ Aluminum Sales ,
Anti-Subsidies ,
Canada ,
Child Labor ,
China ,
Countervailing Duties ,
Customs and Border Protection ,
Department of Labor (DOL) ,
ECCNs ,
Electric Vehicles ,
Enforcement ,
Export Controls ,
False Claims Act (FCA) ,
Forced Labor ,
Fraud ,
Imports ,
ITAR ,
Manufacturers ,
Popular ,
Risk Mitigation ,
Section 301 ,
Solar Panels ,
Steel Industry ,
Surtax ,
Tariffs ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies ,
USTR ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Whistleblowers
On July 29, the Directorate of Defense Trade Controls (DDTC) of the US Department of State proposed a new definition of the term “defense service.”
The International Traffic in Arms Regulations (ITAR) imposes a license...more
On July 29, the US government proposed big changes to rules about supporting or exporting to foreign military, intelligence, and security entities.
The US Department of Commerce’s Bureau of Industry and Security (BIS) is...more
Welcome to the July 2024 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more
7/16/2024
/ Aluminum Sales ,
Chevron Deference ,
Chevron v NRDC ,
Customs and Border Protection ,
Economic Sanctions ,
Enforcement ,
Export Controls ,
Forced Labor ,
Foreign Investment ,
Imports ,
International Trade Commission (ITC) ,
Loper Bright Enterprises v Raimondo ,
Mexico ,
Proposed Rules ,
Russia ,
SCOTUS ,
Steel Industry ,
U.S. Treasury
Three US agencies – the US Department of Commerce, Bureau of Industry and Security (BIS), the US Department of the Treasury, Office of Foreign Assets Control (OFAC), and the US Department of State – took new actions on June...more
6/17/2024
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Harmonization Rules ,
Infrastructure ,
Licenses ,
Licensing Rules ,
Mobile Devices ,
Office of Foreign Assets Control (OFAC) ,
Personal Information ,
Popular ,
Russia ,
Savings Clause ,
SDN List ,
Software ,
US State Departments
The US Government just placed Australia and the United Kingdom (UK) in nearly the same position as Canada for dual-use exports under the Export Administration Regulations (EAR) and is poised to go even further with a proposed...more
5/8/2024
/ Australia ,
Commerce Control List ,
Corporate Counsel ,
Directorate of Defense Trade Controls (DDTC) ,
Dual Use Goods ,
Export Administration Regulations (EAR) ,
Exports ,
ITAR ,
NISPOM ,
Popular ,
Proposed Regulation ,
UK
License Exception MED, published by the US Department of Commerce’s Bureau of Industry and Security (BIS) on April 25, authorizes the export, reexport, or in-country transfer of EAR99 “medical devices” to non-military...more
Two years after the start of Russia’s war in Ukraine and one week after the death of opposition politician and anticorruption activist Aleksey Navalny, the US government announced a new raft of sanctions and export controls...more
On January 25, almost two years after Russia’s further invasion of Ukraine, the US Department of Commerce, Bureau of Industry and Security (BIS) issued a final rule (the Rule) strengthening existing export controls relating...more
1/31/2024
/ Aircraft ,
Belarus ,
Bureau of Industry and Security (BIS) ,
Drones ,
ECCNs ,
Export Administration Regulations (EAR) ,
Export Controls ,
Final Rules ,
Licensing Rules ,
Military Conflict ,
Russia ,
Tariffs ,
U.S. Commerce Department
Just in case you were starting to get comfortable with last year’s massive raft of regulations on the advanced computing, supercomputer, and semiconductor industries in China, the US Department of Commerce, Bureau of Industry...more
During the G7 meeting in Japan on May 19, 2023, the US Department of Commerce’s Bureau of Industry and Security (BIS) published two new rules aimed at further restricting Russia’s ability to obtain items needed to support its...more
6/7/2023
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Export Administration Regulations (EAR) ,
Export Controls ,
G7 ,
Office of Foreign Assets Control (OFAC) ,
Petroleum ,
Russia ,
SDN List ,
U.S. Commerce Department ,
Ukraine
Voluntary No More -
In taking steps to take the “voluntary” out of voluntary disclosure, Assistant Secretary of US Export Enforcement Matthew Axelrod issued another memorandum on April 18, 2023, following on his June 2022...more
On Friday, February 24, the one-year anniversary of Russia’s further invasion into Ukraine, President Biden, the Office of Foreign Assets Control (OFAC), the US Department of State, and the US Department of Commerce, Bureau...more
3/1/2023
/ Banking Sector ,
Belarus ,
Bureau of Industry and Security (BIS) ,
Duties ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Huawei ,
Imports ,
Metals ,
Mining ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Tariffs
On October 28, 2022, the US Department of Commerce, Bureau of Industry (BIS) issued FAQs on the new semiconductor regulations. The FAQs are short and relatively clear (thank you!) even if they were released on a Friday...more
On Friday, October 7, 2022, the Bureau of Industry and Security (BIS) released an interim final rule containing an enormous set of export controls that will likely damage the Chinese semiconductor, advanced computing, and...more
10/11/2022
/ Bureau of Industry and Security (BIS) ,
China ,
Corporate Counsel ,
ECCNs ,
Export Administration Regulations (EAR) ,
Export Controls ,
Federal Register ,
Interim Final Rules (IFR) ,
License Applications ,
Manufacturers ,
Military End Use ,
MOFCOM ,
Popular ,
Rulemaking Process ,
SDN List ,
Semiconductors ,
Software ,
Technology
Well, the Bureau of Industry and Security (BIS) waited until the summer was over, but timing may be the best part of the new export controls on Russia and Belarus (the “Rule”). Understanding the new Rule and how the old...more
9/27/2022
/ Anti-Terrorism Financing ,
Belarus ,
Biological-Weapons ,
Bureau of Industry and Security (BIS) ,
Chemical Weapons ,
Corporate Counsel ,
ECCNs ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Direct Product Rule ,
Military End Use ,
Popular ,
Russia
In an exciting turn of events in the world of the International Traffic in Arms Regulations (ITAR), the US Department of State, Directorate of Defense Trade Controls issued two open general licenses (OGLs) authorizing the...more
On May 8, 2022 (aka Mother’s Day), the Biden Administration announced yet another series of export controls and sanctions measures intended to ratchet up the costs on Russia’s economy and limit its ability to continue its war...more
5/11/2022
/ Accounting ,
Belarus ,
Blocking Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Trusts ,
U.S. Treasury ,
Ukraine
Watch Out, More Things Are Luxury Than You Think!
On March 11, 2022, the President issued Executive Order 14068 (EO 14068) Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian...more
3/15/2022
/ Belarus ,
Economic Sanctions ,
Energy Sector ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
Imports ,
Most-Favored Nations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions ,
U.S. Treasury ,
Ukraine
ArentFox Schiff sanctions advisors Kay Georgi and Matthew Tuchband talk with WorldSmart co-hosts Hunter Carter and Malcolm McNeil about greatly expanded export controls, blocking sanctions, and banking sanctions in response...more
In a coordinated effort, on March 2, 2022, the White House announced another round of broad trade controls and sanctions against Russia and now Belarus in response to Russia’s military invasion of Ukraine.
The White House...more
3/7/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
Foreign Direct Product Rule ,
Licenses ,
Military End Use ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
U.S. Commerce Department ,
Ukraine