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Summer Vacation’s Over: Commerce Imposes New Russia and Belarus Export Controls

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

US Blocks More Russian Elites, Imposes Import Restrictions on Energy & More, Adds Export Controls on Luxury Goods

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

US Sanctions Belarus and Piles on More Russian Sanctions: What You Need to Know

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

OFAC Latest Steps: Blocking Putin and Senior Officers, Further Targeting Sovereign Russian Financial Entities, and Publishing...

On February 25 and 28, 2022, the US Treasury Department, Office of Foreign Assets Control (OFAC) issued its fifth and sixth actions against Russia, blocking the assets of President Vladimir Putin and three other high-ranking...more

Unprecedented Broad Export Controls and Sanctions on Russia Go into Effect – (Some) Immediately!

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

US Imposes Territorial Sanctions on Ukrainian Breakaway Republics & Broader Russia Based Sanctions: What You Need to Know

Responding to the Russian announcement recognizing the independence of the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine, President Biden signed Executive Order 14065 (the...more

Sleeper Trump Rule on ‘Military-Intelligence End Uses or Users’ Goes Into Effect

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

‘Foreign Adversaries’ In Tech Supply Chain May Be Under the Microscope

The Information and Communications Technology and Services (ICTS) Rule, if implemented by the Biden Administration, would significantly impact companies that have an international nexus in a number of different sectors,...more

US Expands Military License Review Factors for National Security Controlled Items to PRC, Venezuela, and Russia

The US Department of Commerce, Bureau of Industry and Security (BIS) issued a final rule amending the license review policy for items on the Commerce Control List that are controlled for national security (NS) reasons and are...more

RIP CIV! BIS to Remove License Exception CIV from the EAR

Rumors have circulated through the export community for months, and the Bureau of Industry and Security (BIS) has finally acted. In a final rule published April 28, 2020, BIS is removing License Exception Civil End-Users...more

Ahoy, Exporters to China, Russia, and Venezuela! Massive Military End Use/User Controls & Reporting Icebergs Lie Ahead!

In yet another action on April 28, 2020, the Bureau of Industry and Security (BIS) issued a final rule imposing stricter license requirements on a wide range of exports, reexports and transfers to China, Russia, or Venezuela...more

OFAC’s COVID-19 Response: Existing Exceptions, Filing and Compliance Flexibility, and a Little Loosening on Iran

Recognizing that COVID-19 is further straining humanitarian needs in sanctioned countries and complicating compliance with economic sanctions, and perhaps also in response to reports that US sanctions are hindering COVID-19...more

Second Shoe Drops on US Chem-Bio Sanctions on Russia: Did Anyone Hear It?

On Friday, August 2, 2019, the US State Department announced the issuance of another round of sanctions on the Russian Government in relation to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991...more

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