Export Controls & Sanctions

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EU Lifts Key Sanctions on Syria: Legal and Compliance Implications Amid Evolving Opportunities

Earlier this week, the Council of the EU adopted a series of legal instruments giving effect to what had been agreed on 20 May 2025, to significantly reduce sanctions on the Syrian Arab Republic. As a result, all EU economic restrictive measures targeting Syria have been lifted, except for those maintained on specific security-related grounds. … Continue Reading

EU Adopts 17th Sanctions Package Against the Russian Federation: Further Targets the “Shadow Fleet” and Expands Export Controls

On 20 May 2025, the European Council announced its 17th sanctions package against the Russian Federation. The latest measures reinforce the EU’s strategic objective of undermining Russia’s capacity to finance and sustain its war efforts in Ukraine.… Continue Reading

A Summary of China’s Retaliation Actions Since The Trump Administration

This summary helps to navigate the various retaliation actions China has taken in the past 50 days after President Trump took office on January 20, 2025, to counter the US trade restrictions, including (i) imposing additional tariff on certain US origin products, (ii) adding 12 US companies to the Unreliable Entity List, (iii) control of … Continue Reading

The EU Suspends Certain Sanctions on Syria to Support Economic Stabilisation, Political Transition and Reconstruction

To help the Syrian people achieve a peaceful and inclusive political transition, to aid the swift economic recovery and reconstruction of the country and to facilitate its eventual reincorporation into the global financial system, the EU has suspended with immediate effect a number of sanctions and restrictive measures that had targeted key sectors of the … Continue Reading

The EU Strengthens Sanctions Against Russia with 15th Package of Restrictive Measures

On 16 December 2024, the European Union (EU) adopted its 15th package of sanctions against Russia in response to its ongoing aggression toward Ukraine. The new measures target key sectors of Russia’s military-industrial complex, including the “shadow fleet” and companies that support this complex. In a significant development, the EU has imposed fully-fledged sanctions – … Continue Reading

Key Updates on the Enhanced Due Diligence and Circumvention Requirements Under Council Regulation 833/2014

On 11 December 2024, the European Commission issued important updates to its Consolidated FAQs on the implementation of Council Regulation No 833/2014 and Council Regulation No 269/2014 (FAQs). These updates cover multiple topics, including due diligence requirements, circumvention and the introduction of a new chapter dedicated specifically to enhanced due diligence for operators involved in … Continue Reading

US Outbound Investment Regulations to Take Effect on January 2, 2025

On October 28, 2024, the Department of the Treasury’s (Treasury) Office of Investment Security issued a final rule[1] (“Final Rule” or “Outbound Investment Regulations”) containing the regulations that will implement, effective on January 2, 2025, an outbound investment regulatory regime that captures certain types of US person-involved investments in, or with, Chinese interests if the … Continue Reading

Navigating DoD’s CMMC Program Final Rule

On October 15, 2024, the U.S. Department of Defense (DoD) released its final rule to establish the Cybersecurity Maturity Model Certification (CMMC) Program (Final CMMC Program Rule). The CMMC Program allows the DoD to verify that defense prime contractors and subcontractors (defense contractors) have implemented security safeguards for Federal Contract Information (FCI) and Controlled Unclassified … Continue Reading

PVH Facing the Risk of Being Placed on China’s Unreliable Entities List

On September 24, 2024, China’s Ministry of Commerce (MOFCOM) announced that the Working Mechanism of the Unreliable Entities List (the “Working Mechanism”) had initiated an investigation of the PVH Group, a global clothing company and owner of brands such as Tommy Hilfiger, Calvin Klein, Warner’s, Olga and True & Co. The action was taken pursuant … Continue Reading

G7 Issues New Recommendations to Prevent Circumvention of Sanctions Against Russia

The primary objective of this guidance is to ensure industry compliance with export controls and help businesses identify risks associated with circumvention of export restrictions directed against the Russian military-industrial complex. The joint guidance identifies the following priority areas: (i)products posing an increased risk of reexport to Russia; (ii) red flag indicators of potential export … Continue Reading

BIS Issues Rule on Implementation of Export Controls on Several Advanced Technologies

On September 5, 2024, the Bureau of Industry and Security (BIS) issued an Interim Final Rule (IFR) implementing export controls on several semiconductor, quantum and additive manufacturing items, as well as Gate-All-Around Field-Effect Transistor (GAAFET) technology. This long-awaited rule is largely aimed at preventing China and other foreign adversaries from advancing their artificial intelligence (AI) capabilities, … Continue Reading

DoD Advances CMMC: Key Takeaways from the Proposed August 2024 DFARS Rule

On August 15, 2024, the US Department of Defense (DoD) published a proposed rule to amend the Defense Federal Acquisition Regulation Supplement (DFARS) in order to implement the Cybersecurity Maturity Model Certification (CMMC) program. DoD is executing a phased rollout of CMMC, and the August 2024 proposed rule is the second proposed rule DoD has … Continue Reading

US Department of State Proposes New Rule to Revise Definition of Defense Service in the ITAR

On July 29, 2024, the US Department of State published a new proposed rule to revise the definition of defense service in the International Traffic in Arms Regulations (22 CFR parts 120-130, “ITAR”) in the Federal Register.  Interested parties are invited to submit comments to the State Department through September 27, 2024.… Continue Reading

EU Expands Sanctions Regime Against Republic of Belarus After 14th Package of Sanctions on Russia

On 29 June 2024, the Council of the EU extended its restrictive measures against Republic of Belarus (Belarus) due to its involvement in Russia’s continued aggression against Ukraine. These measures aim to prevent Belarus from facilitating the evasion of sanctions against Russia and are in line with the EU’s recent efforts to strengthen existing prohibitions … Continue Reading

BIS Amends the EAR to Expand Sanctions Against Russia and Belarus and Over 300 New Sanctions Designations

On June 12, 2024, the US Department of Commerce Bureau of Industry and Security (BIS) imposed additional export control measures against Russia and Belarus by expanding the scope of items subject to the Export Administration Regulations (EAR) sectoral sanctions. The amendments to the EAR were issued in conjunction with the issuance of sanctions against over … Continue Reading

The Russian Federation’s Introduced Compensation Protocol in Response to the Unfriendly Acts of the US

The government of the Russian Federation is taking specific actions to establish a special procedure for compensation of damage caused by the US. Thus, this new procedure enables “Russian Rights Holders” (i.e., holders of damaged rights of the Russian Federation and/ or the Russian Central Bank) to address Russian courts with a statement claiming having … Continue Reading

In-Person Event: US Export Controls Workshops in the UK – July 16-18, 2024

From EAR to ITARnity: Ever-Challenging US Export Controls Compliance When: July 16-18, 2024 Where: Stratford-upon-Avon, UK This hugely successful and highly praised event on US export controls regulations, which is jointly organised by Export Group for Aerospace, Defence & Dual-Use (EGADD) and Squire Patton Boggs, will be celebrating its 17th Anniversary when it takes place in … Continue Reading

White House Issues Executive Order to Strengthen Cybersecurity at US Ports

On February 21, 2024, the White House issued an executive order implementing various measures to bolster the security of US ports by expanding the US Coast Guard’s authority to regulate maritime cybersecurity, requiring the reporting of cyber incidents and investing in the US port critical infrastructure. With the increasing use of connected systems in the … Continue Reading

BIS Amends the EAR To Implement Additional Sanctions Against Russia and Belarus and To Revise Existing Export Controls on Russia, Belarus and Iran

On January 25, 2024, the US Department of Commerce Bureau of Industry and Security (BIS) published amendments to the Export Administration Regulations (EAR) expanding the sanctions against Russia and Belarus through new and revised licensing requirements. The amendments also refined existing export controls on Russia, Belarus and Iran to enhance the effectiveness of, and better … Continue Reading

Forced Labor Legal Developments in Europe: EU Council and Parliament Negotiate Final Text for Proposed Regulation

While many have focused in recent months on the US enforcement of the forced labor import ban (19 U.S.C. 1307) and the Uyghur Forced Labor Prevention Act (UFLPA) (Public Law No. 117-78), the EU is working on its own set of regulations prohibiting products made with forced labor from entering the EU market. A proposal … Continue Reading

Department of Defense Updates Section 1260H Chinese Military Companies List

On January 31, 2024, the Department of Defense (DOD) released an update to the Chinese Military Company (CMC) List in accordance with Section 1260H of the National Defense Authorization Act (NDAA) for Fiscal Year 2021. DOD added sixteen entities to the 1260H CMC List and removed three previously designated entities that no longer met “some … Continue Reading

Semiconductor and Advanced Computing Export Control Rules Modifying and Reinforcing the Restrictions Initially Released on October 7, 2022

Today, the Department of Commerce’s Bureau of Industry and Security (BIS) released three rules to update the export controls issued on October 7, 2022, for advanced computing semiconductors, semiconductor manufacturing equipment, and items that support supercomputing applications and end-uses. We provide a top-line analysis of each of the following rules in turn: As these interim final … Continue Reading

Upcoming Changes in U.S. Export Controls on Advanced Semiconductors & Related Tooling and Recent Development on U.S. Relief Given to Asian Chips Manufacturers 

The landscape of U.S. export controls on advanced semiconductors and related toolings is evolving, with anticipated changes potentially impacting the business operations of companies throughout the global supply chain for products driven by advanced semiconductors and the development of similarly supported technologies. … Continue Reading
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