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
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
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
What Are the New US Export Controls on Russia?
On February 24, 2022, the US Department of Commerce, Bureau of Industry and Security (BIS) imposed new export controls intended to restrict access to technologies and other...more
2/28/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
ECCNs ,
Economic Sanctions ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine
In this WorldSmart podcast, International Trade & Investment Practice Leader Kay Georgi discusses the current and future issues of export controls and economic sanctions, with International Group Co-Chairs Hunter Carter and...more
11/24/2021
/ Automotive Industry ,
Coronavirus/COVID-19 ,
Country of Origin ,
Economic Sanctions ,
Export Controls ,
Exports ,
Free Trade Agreements ,
Importers ,
International Criminal Court ,
International Travel ,
Personal Protective Equipment ,
Tariffs ,
Trade Policy ,
Trade Relations ,
Trade Restrictions ,
Trade Wars ,
United States-Mexico-Canada Agreement (USMCA) ,
Virus Testing ,
WTO
Companies should be prepared to conduct additional due diligence for any transactions involving entities in the countries enumerated in this rule.
In an interim rule published on, January 15, 2020, the Department of...more
3/17/2021
/ Biological-Weapons ,
Bureau of Industry and Security (BIS) ,
Chemical Weapons ,
China ,
Cuba ,
Due Diligence ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Entities ,
Interim Final Rules (IFR) ,
Iran ,
North Korea ,
Nuclear Weapons ,
Russia ,
Syria ,
Trump Administration ,
U.S. Commerce Department ,
Venezuela
Changes are afoot for key industry sectors with complicated global supply chains.
“As this pandemic has made clear, we can never again be in a position where we have to rely on a foreign country that doesn’t share our...more
3/1/2021
/ APIs ,
Batteries ,
Biden Administration ,
CFIUS ,
China ,
Coronavirus/COVID-19 ,
Defense Sector ,
Energy Sector ,
Executive Orders ,
Export Controls ,
Information and Communication Technology (ICT) ,
Minerals ,
Personal Protective Equipment ,
Popular ,
Public Health ,
Risk Management ,
Semiconductors ,
Supply Chain ,
Transportation Industry
The US Department of Commerce Bureau of Industry and Security (BIS) has proposed a new ECCN, 2D352 to control “software” that is capable of being used to operate nucleic acid assemblers and synthesizers due to concerns the...more
On Friday, May 15, 2020, the Department of Commerce and the Bureau of Industry and Security (BIS) revised an arcane export control rule that imposes US export controls on foreign-origin products (hardware, software, and...more
As the COVID-19 pandemic has expanded exponentially, so too has the demand by hospitals and other healthcare providers for masks and other medical personal protective equipment (PPE) to protect doctors, nurses, and other...more
5/14/2020
/ Azerbaijan ,
Cambodia ,
Coronavirus/COVID-19 ,
Export Bans ,
Export Controls ,
Exports ,
Medical Supplies ,
Personal Protective Equipment ,
Public Health Emergency ,
Rescission ,
Sri Lanka
On April 28, the Bureau of Industry and Security (BIS) issued a proposed rule that would revise License Exception Additional Permissive Re-Exports (APR) to remove a current provision that allows for reexports of items subject...more
As the COVID-19 pandemic has expanded exponentially, so too has the demand by hospitals and other healthcare providers for masks and other medical personal protective equipment (PPE) to protect doctors, nurses, and other...more
4/22/2020
/ Argentina ,
Coronavirus/COVID-19 ,
Costa Rica ,
Export Controls ,
FEMA ,
Global Economy ,
Guide ,
Health Care Providers ,
Imports ,
Infectious Diseases ,
Kuwait ,
Moldova ,
Paraguay ,
Personal Protective Equipment