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US Government Contracts Quick Hit Briefing: Small Business Runway Extension Act Becomes Law, Yet Implementation Halted by Government Shutdown

On December 17, 2018, President Trump signed into law the Small Business Runway Extension Act of 2018 (HR 6330) (the Act), which modifies the period to measure small business size status from three fiscal years of average annual receipts to five fiscal years.… Continue Reading

US-EU Export Controls and Sanctions Alert: In Case of Hard Brexit, EU and UK Issue Plans for Export of Dual-use Goods

Due to the vacillating political developments in the UK, a “hard Brexit” scenario (meaning, no withdrawal agreement reached between the EU and UK by the withdrawal date of March 30, 2019) is likely to happen. In preparation for a no-deal withdrawal, which would affect the trade of dual-use items between the EU and the UK, the European Commission (the Commission) … Continue Reading

How Do You, Your Suppliers and Customers Fare as Trade Tensions Escalate?

UPDATE: The Tariff Book was updated again on December 17, 2018. Changes were made to the US section. How To Use The Tariff Book Because there is so much information included in this Tariff Book, we have made the document fully searchable. The information provided in this book comes from number of different sources, some of which are … Continue Reading

EU Adopts CFIUS-like Framework for Sake of National Security

EU goes ahead with a European framework, similar in intents and purposes as the Committee for Foreign Investments in the United States (CFIUS), for screening incoming foreign direct investments… extra scrutiny over foreign investments that might affect public order and security. On December 10, 2018, the European Parliament Committee on International Trade (INTA) approved the EU Regulation establishing a framework for screening of … Continue Reading

OFAC Offers Temporary Extension of Ukraine-related General Licenses

On September 21, 2018, OFAC extended certain Ukraine-related general licenses. OFAC issued General License No. 13D authorizing certain transactions necessary to divest or transfer debt, equity, or other holdings in listed blocked persons. OFAC also issued General Licenses No. 14A and 16A, which authorize certain activities necessary to the maintenance or wind down of operations or existing contracts with 1) United … Continue Reading

BIS Announces Revisions to Export Administration Regulations (EAR)

On August 30, 2018, the Bureau of Industry and Security (BIS) published in the Federal Register a final rule titled, “Revisions to the Export Administration Regulations Based on the 2017 Missile Technology Control Regime Plenary Agreements.” This new final rule amending the EAR reflects changes to the Missile Technology Control Regime (MTCR) Annex pursuant to the October 2017 agreement by the … Continue Reading

Regulatory Revisions to International Traffc in Arms Regulations (ITAR)

On October 4, 2018, the Directorate of Defense Trade Controls (DDTC) announced in the Federal Register revisions to the ITAR titled, “Regulatory Reform Revisions to the International Traffic in Arms Regulations.” The revisions are in response to comments that the Department of State received. The new rule has removed certain notification requirements from the ITAR, and it removed certain items … Continue Reading

Trump Administration Issues CAATSA-related Executive Order

On September 20, 2018, President Trump issued a new CAATSA-related Executive Order (EO) titled, “Authorizing the Implementation of Certain Sanctions Set Forth in the Countering America’s Adversaries Through Sanctions Act” and an accompanying frequently asked question. This EO provides authority to the Secretary of Treasury to take certain actions to implement certain sanctions under the Countering America’s Adversaries Through Sanctions … Continue Reading

UK Provides Guidance on Exporting Controlled Goods if There is No Brexit Deal

The Department for International Trade has produced guidance, published on August 23, 2018, informing stakeholders how export controls would be affected if the UK leaves the EU with no deal. The notice explains how export licensing requirements for different groups of items would change and what the UK government proposed to simplify licensing. The export of many controlled items within … Continue Reading

ECJU Amends Export Control Order 2008 and Publishes Firearms Export Guidance

The export control joint unit (ECJU) has amended the Export Control Order 2008 with effect from September 14, 2018. The new Order extends the controls on firearms to include devices capable of being converted to firearms. The ECJU has also updated the consolidated control list of strategic military and dual-use items that require export authorization. The additional devices include the … Continue Reading

OFSI Updates Financial Sanctions

The Office of Financial Sanctions Implementation (OFSI), which is part of HM Treasury and works to ensure that financial sanctions are properly implemented and enforced in the UK, has  updated a number of financial sanctions currently in force. The recent updates are as follows: Financial sanctions, Libya; Financial sanctions, Ukraine (Sovereignty and Territorial Integrity); Financial sanctions, North Korea (Democratic People’s … Continue Reading
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