Export Controls & Sanctions

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

By Trade Practitioner on Posted in Customs, Enforcement Actions, EU, Export Controls & Sanctions, Tariffs, Trade Policy & Market Access, Trade Remedy & Defense, US, US 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

By Trade Practitioner on Posted in Export Controls & Sanctions, Trade Policy & Market Access, US Regulation
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

By Trade Practitioner on Posted in Export Controls & Sanctions
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 

By Pablo Carrillo, Edward Newberry, George Grammas, Peter C. Alfano III, Ludmilla Kasulke, Kara-Marie Urban and Dominic Braithwaite on Posted in Export Controls & Sanctions, Trade Policy & Market Access
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

OFAC Expands Russian Sanctions

By Trade Practitioner on Posted in Export Controls & Sanctions, Russia
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

By Trade Practitioner on Posted in Export Controls & Sanctions, Technology Transfer, US Regulation
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

By Trade Practitioner on Posted in Export Controls & Sanctions, Iran, Russia
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

By Trade Practitioner on Posted in Events, Export Controls & Sanctions
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

By Trade Practitioner on Posted in Artificial Intelligence, Export Controls & Sanctions
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

By Trade Practitioner on Posted in Artificial Intelligence, China, Export Controls & Sanctions, US
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

By Trade Practitioner on Posted in Europe & Central Asia, Export Controls & Sanctions, Russia
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

By Trade Practitioner on Posted in Events, Export Controls & Sanctions, US
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

By Trade Practitioner on Posted in Events, Export Controls & Sanctions, US
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

By Trade Practitioner on Posted in Export Controls & Sanctions
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

By Trade Practitioner on Posted in Export Controls & Sanctions, Russia
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

By Trade Practitioner on Posted in Events, Export Controls & Sanctions, United Kingdom, US
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

By Trade Practitioner on Posted in Export Controls & Sanctions, Russia, Ukraine, US Regulation
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

By Trade Practitioner on Posted in Export Controls & Sanctions, Russia, Ukraine
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
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