Export Controls & Sanctions

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

By Trade Practitioner on Posted in China, Customs, Enforcement Actions, Export Controls & Sanctions, Trade Policy & Market Access
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

By Trade Practitioner on Posted in European Regulations, Export Controls & Sanctions
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

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

By Trade Practitioner on Posted in Export Controls & Sanctions, Government Contracts, US Regulation
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

By Trade Practitioner on Posted in Export Controls & Sanctions
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

By Trade Practitioner on Posted in Export Controls & Sanctions
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

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

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

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

By Trade Practitioner on Posted in China, Enforcement Actions, EU, Export Controls & Sanctions, Technology Transfer, Trade Policy & Market Access, US, US Regulation
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

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

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
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