On March 25, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a significant expansion of its Entity List restrictions, adding 80 entities from China, the United Arab Emirates, South Africa,...more
Governments have long regulated international trade in goods, technology, and investment for purposes of revenue generation, economic policy, and national security....more
On January 15, 2025, BIS issued an interim final rule controls targeting integrated circuits (“ICs”) fabricators. BIS is concerned that some IC designers have misrepresented the performance capabilities and intended end use...more
In one of the first enforcement actions of 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order against Haas Automation, Inc., a leading manufacturer of computer numerical...more
The U.S. Commerce Department and other regulatory agencies published regulations at a furious pace as the Biden administration came to a close this month. These new regulations appear to be primarily aimed at restricting...more
On December 2, 2024, the U.S. Department of Commerce Bureau of Industry and Security (“BIS”) issued two new rules further restricting China’s capability to produce advanced semiconductors. One final rule (the “Entity List...more
On January 2, 2025, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) Export Enforcement published its 2024 Year in Review, spotlighting key accomplishments in protecting U.S. national security. In this...more
As global economic and geopolitical environments enter a new era, companies need to continuously develop and adjust their coherent global business strategies to secure and further expand business opportunities in all markets...more
Our International Trade & Regulatory Group discusses the latest U.S. export controls on China’s advanced computing, supercomputer, and semiconductor sectors....more
The U.S. Bureau of Industry and Security (BIS) on Dec. 2, 2024, issued a Final Rule, "Additions and Modifications to the Entity List; Removals From the Validated End-User (VEU) Program" (Final Rule), and an Interim Final Rule...more
Although the Trump transition is well underway, the Biden administration made news in the national security space by announcing significant new export restrictions on semiconductor equipment and technology destined for the...more
On December 2, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) released its third round of export controls primarily targeting China’s attempts to create an “independent and controllable”...more
In October 2024, the Bureau of Industry and Security (“BIS”) issued new guidance to financial institutions (“FIs”) on best practices for compliance with the Export Administration Regulations (“EAR”). This guidance outlines...more
On November 1, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a $500,000 monetary penalty on GlobalFoundries U.S. 2 LLC and its parent, GlobalFoundries U.S. Inc., for a series of...more
On August 15, 2024, the U.S. Department of Commerce’s Office of Export Enforcement (“OEE”) announced the settlement of the latest administrative enforcement action involving TE Connectivity Corporation—a Pennsylvania-based...more
Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance to exporters intended to further assist BIS in its efforts to crack down on third-party diversion to Russia. ...more
On July 18, 2024, the U.S. Dept. of Commerce, Bureau of Industry and Security (BIS) published a new interim final rule (the “Interim Final Rule”) entitled “Standards-Related Activities and the Export Administration...more
Typically, the Bureau of Industry and Security (BIS) within the U.S. Department of Commerce administers export controls on end users by designating those persons on one of its public screening lists—e.g., the Unverified List,...more
On July 10, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released new guidance (the “July 10 Release”) outlining different types of precautionary letters (“supplier list” letters, “Project...more
On July 18, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule (IFR) amending the U.S. Export Administration Regulations (EAR) so that certain technology and software...more
The U.S. government’s primary export control regulator – the Bureau of Industry and Security (BIS) within the Commerce Department – issued a new rulemaking to remove barriers from U.S. companies’ participation in...more
As we pass the midpoint of a year marked by assertive enforcement of dual use laws, the Department of Commerce’s Bureau of Industry and Security (BIS) published an updated version of its Don’t Let This Happen to You! Guide....more
On June 27, 2024, the U.S. Department of Commerce, Bureau of Industry & Security (BIS) announced its first update to the boycott requester list. The list contains entities that have been reported by a U.S. person as having...more
On June 20, the Department of Commerce’s Bureau of Industry and Security (BIS) for the first time banned a software and cybersecurity company using authority provided by June 2023’s “Protecting Americans’ Sensitive Data from...more
We all know what a “core” sanctions violation looks like. The heartland of such misconduct has been described on numerous occasions in OFAC enforcement actions and settlements. In this environment, however, companies have...more