ITAR for Facility Security Officers
ITAR for Government Contractors - New Developments for 2018
In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. ...more
In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic sanctions imposed by...more
Since February 24, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has implemented numerous new export control restrictions in response to the invasion of Ukraine by the Russian Federation...more
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
Earlier this week, following Russia’s aggressive incursion into Ukraine, we reported on the imposition of U.S. sanctions in response — a modest response that reserved the heavier sanctions that have been anticipated. On...more
The U.S. government recently took action in two cases against companies for exports to distributors that resold their products to prohibited parties. The products at issue in both cases are designated "EAR99," which is a...more
On 15 January 2021, the Bureau of Industry and Security (BIS) published an interim final rule imposing new restrictions requiring licenses for transactions involving exports, reexports, or transfers, as well as certain...more
Today the Bureau of Industry and Security (BIS) added 24 Chinese state-owned companies to the Entity List for their role in the construction of artificial islands in the South China Sea. The Entity List prohibits the export,...more
On August 20, the Bureau of Industry and Security (“BIS”) published a final rule (“final rule”) amending the Export Administration Regulations (“EAR”) to expand restrictions on transactions involving Huawei entities that are...more
The U.S. government is expanding international trade restraints against Huawei Technologies Co. Ltd. (“Huawei”) and its affiliates in an effort to further restrict Huawei’s access to U.S. technologies.....more
- The U.S. Department of Commerce has published a highly complex and novel interim final rule extending the controls of the Export Administration Regulations (EAR) over foreign-made items in Huawei’s contract manufacturing...more
On May 15, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule amending the Export Administration Regulations (EAR) to prohibit the supply of certain foreign-produced...more
The Commerce Department’s Bureau of Industry and Security has announced an Interim Final Rule amending the Export Administration Regulation’s General Prohibition Three, the foreign-produced direct product rule....more
As of 16 March 2020 Iran Air and a number of other entities were placed on the Bureau of Industry and Security's (BIS) Entity List. Summary - Companies that use Iran Air as transport, particularly companies engaging in...more
The title of this article is based on a line in an old song, “Everybody’s Crying Mercy,” by Mose Allison. As modified, the couplet captures the cognitive dissonance that many are feeling as a result of the federal...more
Effective October 9, 2019, the U.S. Department of Commerce has added 28 Chinese entities to the prohibited Entity List, including large technology, artificial intelligence and science companies. Notable among the additions...more
On August 19, 2019, the Department of Commerce Bureau of Industry and Security (“BIS”) announced that it has added 46 additional Huawei Technologies Co., Ltd. (However, although these restrictions make it harder for U.S....more
In May of 2019, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) added Chinese telecommunications giant Huawei Technologies Co. Ltd. (“Huawei”) and sixty-eight of its affiliated companies to BIS’s...more
More Huawei Affiliates Added - Effective August 19, 2019, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) added 46 more non-U.S. affiliates of Huawei Technologies Co. Ltd. of China (collectively...more
• The Commerce Department’s Bureau of Industry and Security (BIS) has added 46 additional Huawei affiliates to the Entity List. The export, reexport, and transfer to these entities of commodities, software, and technology...more
• President Donald Trump saying at the recent G20 Summit in Japan that American companies could keep selling products to Huawei Technologies Co. Ltd. (Huawei) was another installment in the drama surrounding the Chinese tech...more
Consistent with the ongoing United States (US) strategy of limiting engagement with China in the high-tech sector (especially telecommunications) on national security grounds, the US Department of Commerce’s Bureau of...more
• Since the addition of Huawei and many of its affiliates to the Entity List, there has been significant media coverage over which types of transactions involving the listed entities are, and are not, prohibited without a...more
The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce (Commerce) has added Huawei Technologies Co. Ltd. and 68 of its Chinese and global non-US affiliates (the Huawei Group) to the BIS Entity List. ...more
• On May 20, 2019, the U.S. Department of Commerce published a 90-day Temporary General License (TGL) authorizing limited categories of exports, reexports, or transfers that are otherwise prohibited pursuant to the addition...more