Export Controls & Sanctions

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OFAC Expands Russian Sanctions

On May 19, 2023, the Department of Treasury’s Office of Foreign Asset Control (OFAC) expanded U.S. economic sanctions against Russia through the issuance of: In addition, OFAC issued four general licenses related to these expansions. (Recent Actions, Department of Treasury, Russia-related Designations; Issuance of Amended Russia-related Directive 4, Russia-related General Licenses; Publication of Russia-related Determinations; … Continue Reading

BIS Issues Proposed Rule for Section 1758 Technology Export Controls on Instruments for the Automated Chemical Synthesis of Peptides

On April 20, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published in the Federal Register (88 Fed. Reg 24341) a Proposed Rule to implement export controls on certain instruments for the automated synthesis of peptides, which have been identified by BIS as a Section 1758 emerging and foundational technology. Comments … Continue Reading

BIS Amends the EAR to Impose Additional Sanctions Against Russia and Belarus and to Impose Additional Export Controls on Iran

Sanction, toned photoOn Friday, February 24, 2023, the US Department of Commerce, Bureau of Industry and Security (BIS) published in the Federal Register four new Final Rules amending the Export Administration Regulations (EAR) (15 CFR parts 730-774) to implement additional sanctions against Russia and Belarus, refine existing controls, implement export control measures on Iran, and add new entities to the … Continue Reading

In-Person Event: US Export Controls Workshops in the UK – June 26-28, 2023

From EAR to ITARnity: Ever-Challenging US Export Controls Compliance When: June 26 – 28, 2023 Where: Stratford-upon-Avon This hugely successful event on US export controls regulations, which is jointly organized by EGADD and Squire Patton Boggs, will be celebrating its 16th Anniversary when it takes place in June 2023. For this year, the event will, … Continue Reading

DOJ and Commerce Department Launch Disruptive Technology Strike Force

On February 16, 2023, the United States Department of Justice (“DOJ”) announced that the DOJ and the Commerce Department were launching the “Disruptive Technology Strike Force,” to be led jointly by the DOJ’s National Security Division and the Commerce Department’s Bureau of Industry and Security (“BIS”), that “will focus on investigating and prosecuting criminal violations … Continue Reading

BIS Implements New Chinese Supercomputer and Semiconductor Manufacturing Export Controls

On Thursday, October 13, 2022, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) published in the Federal Register an Interim Final Rule, 87 Fed. Reg. 62186, amending the Export Administration Regulations (EAR) (15 CFR parts 730-774) to impose new export controls on Chinese advanced computing integrated circuits (ICs), computer commodities containing such … Continue Reading

BIS Issues New Export Controls on Russia and Belarus

On Friday, September 16, 2022, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) published in the Federal Register a Final Rule, 87 Fed Reg. 57068, amending the Export Administration Regulations (EAR) (15 CFR parts 730-774) to impose several new controls on exports, reexports, and transfers (in-country) of items to or within Russia … Continue Reading

A New Look at US Sanctions and Practical Guidelines for Compliance (Encore presentation on the West Coast) – September 29, 2022

Join us in person at the Embassy Suites Santa Clara – Silicon Valley on September 29 to hear from this select panel of high-level government and industry policy leaders who will explore emerging sanctions and embargoes compliance trends in 2022 and beyond to include:… Continue Reading

A New Look at US Sanctions and Practical Guidelines for Compliance – September 26, 2022

Join us in person at the Schar School of Policy and Government at the George Mason University Arlington Campus on September 26 to hear from this select panel of high-level government and industry policy leaders who will explore emerging sanctions and embargoes compliance trends in 2022 and beyond to include:… Continue Reading

BIS Proposes New US Export Controls on Marine Toxins

On May 23, 2022, the US Commerce Department’s Bureau of Industry and Security (BIS) published in the Federal Register a proposed rule and request for comments. This proposed rule seeks to amend the Export Administration Regulations (EAR) (15 CFR parts 730-774) by adding four dual-use biological toxins to Export Control Classification Number (ECCN) 1C351 on … Continue Reading

Now and Next Podcast Series: Russia/Ukraine Conflict

In our Now & Next podcast series, we spotlight the “Now” (the ongoing global responses to the conflict and crisis in Ukraine) and the “Next” (the immediate- and long-term rippling effects of those responses), as well as what businesses should do now and next to navigate the situation and mitigate their risk exposures. Matthew Kirk, … Continue Reading

US Export Controls Workshops in the UK – June 27-29, 2022

For the past 14 years, we have jointly hosted a successful annual workshop series on US export controls regulations with EGADD. In celebration of its 15th anniversary, this June’s workshop will also be organized in close partnership with BAE Systems, a major, multinational company that has considerable practical experience in dealing with the challenges arising … Continue Reading

US Actions on Russia and Russia-related Sanctions

The US has responded to the conflict in Ukraine with the following sanctions measures (listed by date, beginning with most recent). With relevant developments, we will update this post on a weekly basis. The latest developments occurred on April 1 and April 6. Additional jurisdictions we are tracking include: EU, Japan, Republic of Korea and … Continue Reading

BIS Amends Export Administration Regulations with Respect to Russia and Belarus

On Tuesday, April 12, 2022, the US Department of Commerce, Bureau of Industry and Security (BIS) published in the Federal Register a Final Rule amending the Export Administration Regulations (EAR) (15 CFR parts 730-774) to add four additional countries to the list of countries excluded from certain license requirements (Supp. No. 3 to part 746) … Continue Reading

Russia-related Sanctions and New US Export Controls – Implications for US Trade Contracts and Negotiations

Our Trade Practitioners recently provided an overview on Russia-related sanctions and newly imposed export controls by the US, and shared insights on how to manage US trade contracts and negotiations via two webinars. Please visit our Learning Center for the webinar recordings and presentation slides.… Continue Reading

BIS Issues Final Rule Reorganizing and Clarifying Foreign-Direct Product Rules

On February 3, 2022, the Department of Commerce, Bureau of Industry and Security (“BIS”) published a final rule (the “Final Rule”) reorganizing and clarifying the foreign-direct product (“FDP”) rules.[1]  BIS has consolidated the FDP rules in the previously reserved § 734.9 of the Export Administration Regulations[2] (“EAR”), whereas, before, one was required to reference multiple … Continue Reading

US Commerce Department Adopts Controls on Cyber Intrusion Item; Opportunity for Industry Comment

On October 21, 2021, the US Commerce Department’s Bureau of Industry and Security (BIS) published in the Federal Register an Interim Final Rule with request for comments, that amends the Export Administration Regulations (EAR) (15 CFR Parts 730- 774) regarding export controls on certain cyber intrusion items. Read the full client alert here.… Continue Reading

Blue Lantern Report for FY2020 – The End-Use Monitoring of Defense Articles and Defense Services Program

The Blue Lantern program “monitors the end-use of defense articles, technical data, defense services, and brokering activities exported through commercial channels and subject to [DOS] licenses or other approvals.” On July 6, the Department of State (DOS), Directorate of Defense Trade Controls (DDTC) published a Congressional report on End-Use Monitoring of Defense Articles and Defense … Continue Reading
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