Takeaways - The G7 has announced consensus on a price cap for Russian origin oil and petroleum products to be implemented across a wide coalition of countries....more
On August 15, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule introducing new controls on four “emerging and foundational technologies” that were identified during the...more
On July 13, 2022, as part of a new pilot program, the Department of State’s Directorate of Defense Trade Controls (“DDTC”) issued two open general licenses (“OGLs”) permitting certain reexports and retransfers of unclassified...more
Key Takeaways: The Uyghur Forced Labor Prevention Act (UFLPA) went into effect on June 21, 2022, and requires the U.S. Customs and Border Protection (CBP) to presume that all goods manufactured wholly or in part in the XUAR,...more
On May 8, 2022, the White House announced a number of new measures in response to Russia’s ongoing war in Ukraine. The new measures include prohibitions on new categories of services to Russia by U.S. persons; export controls...more
In the last month, the United States and global allies have issued unprecedented sanctions against Russia in response to the war in Ukraine. These sanctions apply ever-expanding pressure on the Russian economy and touch...more
The EU and UK have imposed additional export controls and sanctions with respect to Russia and Belarus connected to the Russian invasion of Ukraine. Below is a summary of key developments over recent days since our last blog...more
3/3/2022
/ Airspace ,
Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Economic Sanctions ,
Export Controls ,
Foreign Relations ,
Proposed Legislation ,
Russia ,
UK ,
Ukraine
On February 24, 2022, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued a final rule effective immediately imposing sweeping export control restrictions against Russia in response to Russia’s...more
3/3/2022
/ Belarus ,
Belarus Sanctions ,
Bureau of Industry and Security (BIS) ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
General Licenses ,
Licensing Rules ,
Military End Use ,
Russia ,
U.S. Commerce Department ,
Ukraine
Despite months of posturing and growing geopolitical tensions, Russia’s full-scale invasion of Ukraine this week was a shock to the global community. Western leaders have been swift and unanimous in their response, condemning...more
2/28/2022
/ Anti-Money Laundering ,
Asset Freeze ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
ECCNs ,
Economic Sanctions ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
UK ,
Ukraine
On February 24, 2022, the U.S. Government issued a number of sanctions measures in response to Russia’s attack on Ukraine. These measures include sweeping financial sanctions and stringent export controls, which will have...more
2/25/2022
/ Biden Administration ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Embargo ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
U.S. Treasury ,
Ukraine
Will 2022 Be the Year of Supply Chain Ethics?
Effective June 21, 2022, in an effort to address forced labor concerns, U.S. law will broadly prohibit imports of products from China’s Xinjiang Uyghur Autonomous Region...more
1/19/2022
/ China ,
Compliance ,
Customs and Border Protection ,
Due Diligence ,
Enforcement ,
Environmental Social & Governance (ESG) ,
Ethics ,
Forced Labor ,
Human Rights ,
Imports ,
Sanctions ,
Supply Chain ,
Tariff Act of 1930 ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Withhold Release Orders (WROs)
On October 21, 2021, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) announced an interim final rule (Interim Rule), which will amend the Export Administration Regulations (EAR) to add controls for the...more
On August 9, 2021, the one-year anniversary of the claimed reelection of Belarusian leader Aleksandr Lukashenka, President Biden issued an “Executive Order on Blocking Property of Additional Persons Contributing to the...more
On July 30, 2021, the Biden Administration published a Proposed Amendment to the Federal Acquisition Regulation (FAR) (Proposed Rule) that, among other things, would impose significantly increased U.S. content requirements...more
The Biden Administration has signaled an expanded commitment to longstanding U.S. anti-corruption policies, and recent enforcement actions and policy announcements provide insights into what foreign officials, companies and...more
U.S. officials have continued to use a range of policy tools to apply pressure on the military leadership of Myanmar (also known as Burma) in response to the military coup in the country and escalating violence against...more
In response to the recent military coup in Myanmar (also known as Burma) against the democratically-elected government, on February 11, 2021 the Biden Administration issued an Executive Order on Blocking Property with Respect...more
On January 25, 2021, President Biden issued Executive Order (E.O.) 14005 to implement the President’s domestic sourcing and manufacturing policy agenda by tightening federal procurement and contracting requirements and...more
On January 13, 2021, U.S. Customs and Border Protection (CBP) issued a withhold-release order (WRO) on all cotton and tomato products from China’s Xinjiang Uyghur Autonomous Region (XUAR) based on information that reasonably...more
On January 19, 2021, the Commerce Department issued an interim final rule to implement the Executive Order on Securing the Information and Communications Technology and Services Supply Chain (E.O. 13873), which was issued on...more
On December 21, the Bureau of Industry and Security (BIS) published a Military End User (MEU) list to further implement the military end user/end use (MEU) rule defined in Section 744.21 of the Export Administration...more
On December 14, 2020 the Bureau of Industry and Security (BIS) published an interim final rule (Interim Rule) making changes to the process for seeking exclusions from tariffs imposed on steel and aluminum imports under...more
On December 2, 2020, U.S. Customs and Border Protection (CBP) issued an import detention or Withhold Release Order (WRO) against cotton produced by Xinjiang Production and Construction Corps (XPCC) based on information that...more
Despite fundamentally different approaches and worldviews, the candidates make remarkably similar diagnoses of what historical issues must be addressed.
Despite the combative rhetoric over President Trump’s use of tariffs...more
10/30/2020
/ CFIUS ,
China ,
Coronavirus/COVID-19 ,
Donald Trump ,
Fair Trade Agreements (FTA) ,
Foreign Policy ,
Free Trade Agreements ,
International Trade ,
Joe Biden ,
Supply Chain ,
Tariffs ,
Trade Wars ,
Trans-Pacific Partnership ,
United States-Mexico-Canada Agreement (USMCA)
Continuing its “maximum pressure” campaign against Iran, the United States has (a) ratcheted up sanctions under Executive Orders that provide for the imposition of secondary sanctions on non-U.S. companies that engage in...more