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
BIS will be looking at items that are controlled only for anti-terrorism, crime control, short supply, United Nations embargoes, or designated as EAR99 in establishing new Foundational Technologies Controls.
Two years...more
8/28/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Embargo ,
Export Control Reform Act (ECRA) ,
Exports ,
FIRRMA ,
Interim Final Rules (IFR) ,
Military End Use ,
National Security ,
Rulemaking Process ,
United Nations
On August 17, 2020, the Department of Commerce, Bureau of Industry and Security (BIS) issued a final rule (the Final Rule) (1) adding additional Huawei non-US affiliates to the Entity List, (2) confirming the expiration of...more
On Monday, June 29, the Departments of Commerce and State announced that they were following through with changes to treat Hong Kong like China for exports of military and dual-use goods.
The Department of Commerce announced...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
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
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
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
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
4/28/2020
/ Coronavirus/COVID-19 ,
Cuba ,
Economic Sanctions ,
Executive Orders ,
FEMA ,
Humanitarian Assistance ,
Iran ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Secondary Sanctions ,
Syria ,
Ukraine ,
Venezuela
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
The Federal Emergency Management Agency has left many important questions blowing in the wind as a result of a Notification of Exemptions action published for public inspection on Friday, April 17, 2020. The final action will...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
The Federal Emergency Management Agency (FEMA) has exercised its delegated authority under the Defense Production Act (DPA) to issue a temporary final rule (Prioritization and Allocation of Certain Scarce or Threatened Health...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
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
The good news is that, for the most part, State resisted the temptation to do something just a little different in the ITAR regulation, so the joint Commerce-State solution works. The chart below provides a quick side-by-side...more
1/3/2020
/ Cloud Computing ,
Comment Period ,
Encryption ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exporters ,
Interim Final Rules (IFR) ,
ITAR ,
Technology ,
U.S. Commerce Department ,
US Department of State
Under this new evaluation process, Commerce can prohibit companies from engaging in a wide variety of transactions and order them to cease using the information technology or telecommunication system in question even if it is...more
12/3/2019
/ China ,
Comment Period ,
Congressional Oversight ,
Constitutional Challenges ,
Corporate Counsel ,
Digital Services ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Adversaries ,
Information and Communication Technology (ICT) ,
Information Technology ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Risk Management ,
Supply Chain ,
Technology Sector ,
Telecommunications ,
Trump Administration ,
U.S. Commerce Department
On October 23, the President asked the Department of the Treasury to lift previously imposed sanctions against Turkey following the cessation of Turkey’s offensive in Syria and the implementation of a lasting ceasefire....more
BIS has restricted Cuba’s access to commercial aircraft and other goods, lowered de minimis for foreign items containing US content to 10%, and restricted the temporary sojourn by aircraft in Iran, Syria, Sudan, and North...more
10/21/2019
/ Airlines ,
Bureau of Industry and Security (BIS) ,
Cuba ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Policy ,
General Licenses ,
National Security ,
New Rules ,
North Korea ,
State Sponsors of Terrorism ,
Sudan ,
Syria ,
Trade Restrictions ,
Vessels
The US State Department is soliciting feedback on its draft “US Government Guidance for the Export of Hardware, Software, and Technology with Surveillance Capabilities and/or Parts/Know-How,” issued September 4, 2019 (Draft...more
9/25/2019
/ Draft Guidance ,
Due Diligence ,
Emerging Technology Companies ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exporters ,
Exports ,
Human Rights ,
Multinationals ,
Surveillance ,
Technology ,
US Department of State
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