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Footnote Frenzy: Charting Out Commerce’s Proposed Expanded US Person and End Use Export Controls and Facial Recognition Controls

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

As the (Customs and Trade) World Turns: June 2024

Welcome to the June 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

As the (Customs and Trade) World Turns: May 2024

Welcome to the May 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

Commerce Tidies Up the Russia/Belarus Export Controls and Adds Aircraft and Drones (HTS Ch 88) to Its License Requirements

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

Stopping Just Short of the Kitchen Sink, USG Requires Licenses for Exports of Entire HTS Chapters to Russia

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

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

Commerce Department Signals Tough Approach on China Under Controversial Trump Tech Supply Chain EO

The subpoena issuance suggests that the Biden Administration will continue the US Government’s assertive approach to China. The US Department of Commerce, on March 17, 2021, issued subpoenas on multiple Chinese companies...more

US Export Controls: Business as Usual?

Turning to the business of exports from the United States, the next section is a must-read for any company doing business in the United States or from the United States. Or for that matter, any company competing with affected...more

US Administration Takes on Chinese Social Media

President Trump signed an Executive Order (EO) (TikTok EO) August 6, 2020, banning “transactions” yet to be identified by the US Department of Commerce (Commerce) related to TikTok and its parent ByteDance Ltd. Specifically,...more

US Government Hurls Another Export Control Grenade at Huawei

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

ITAR Defense Controls Catches Up to Modern IT, Allowing Exporters to Use Encryption to Protect Defense Technology on the Cloud

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

CFIUS 2.0: Emerging Tech Minority Investments – Expansion of Jurisdictional Scope Remains in Limbo

In FIRRMA and ECRA, Congress essentially gave Commerce authority to decide how narrowly or widely to set the jurisdiction of the Committee on Foreign Investment in the United States (CFIUS) over non-passive minority...more

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