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
On January 5, 2023, the Directorate of Defense Trade Controls (DDTC), which administers the International Traffic in Arms Regulations (ITAR), announced updated guidance and FAQs for US persons abroad (USPAB) authorization requests. DDTC also released a submission letter template and sample § 121.13 certification letter to accompany such requests.… Continue Reading
The U.S. Department of Justice announced late last year that it would utilize the False Claims Act, the U.S. government’s primary civil tool to redress false claims for federal funds and property, to bring actions against U.S. government contractors and subcontractors who do not meet the cybersecurity requirements of a particular contract or grant. DOJ … Continue Reading
On September 13, 2022, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) published in the Federal Register (87 FR 55930) an Advance Notice of Proposed Rulemaking (ANPRM) and request for comments regarding certain instruments for the automated synthesis of peptides (automated peptide synthesizers). This proposed rule seeks to identify such automated peptide synthesizers … Continue Reading
In light of the current conflict and crisis in Ukraine, we are tracking the evolving sanctions imposed by several governments on Russia and Russia-aligned regions and certain individuals. The jurisdictions in focus are: EU, Japan, Republic of Korea, UK and US. Latest Developments:… Continue Reading
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
On June 3, 2021, US President Joseph Biden issued Executive Order 14032, “Addressing the Threat From Securities Investments that Finance Certain Companies of the People’s Republic of China” (EO 14032), substantially amending the prohibitions originally contained in Executive Order 13959 (EO 13959), issued by President Trump on November 12, 2020 (amended January 13, 2021).… Continue Reading
On February 10, 2021, President Biden signed Executive Order (EO) 14014, “Blocking Property With Respect to the Situation in Burma,” which authorized the imposition of sanctions. In the EO, the President declared a national emergency to address the threat following a February 1, 2021 military coup in Burma, whereby the military overthrew the democratically-elected government and … Continue Reading
On March 29, 2021, the US Department of Commerce, Bureau of Industry and Security (BIS) published a Final Rule in the Federal Register amending the Export Administration Regulations (EAR) to reflect the remaining approved 2019 changes to the dual-use controls adopted during the 2019 Wassenaar Arrangement Plenary Meetings. … Continue Reading
On March 18, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) published in the Federal Register a Notification of Implementation pursuant to sanctions imposed by the Secretary of State under Section 306(a) of the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act). … Continue Reading
On February 2, 2021, Department of Commerce’s Bureau of Industry and Security (BIS) announced an administrative settlement of $54,000 with Princeton University.… Continue Reading
On January 29, 2021, Department of Commerce’s Bureau of Industry and Security (BIS) announced an Administrative Settlement of $3.2 million (partially suspended) with Singapore-based Avnet Asia Pte. Ltd. (Avnet Asia), a global distributor of electronic components and related software.… Continue Reading
Department of Commerce’s Bureau of Industry and Security (BIS) announced on January 14, 2021, that it had implemented the Secretary of State’s rescission of Sudan as a State Sponsor of Terrorism (SSOT) by amending the Export Administration Regulations (EAR).… Continue Reading
PT Bukit Muria Jaya (“BMJ”), a global supplier of cigarettes, has agreed to pay a fine of more than $1.5 million and to enter into a deferred prosecution agreement with the Department of Justice (DOJ) for conspiracy to commit bank fraud in connection with the shipment of products to North Korean customers.… Continue Reading
What are the implications? What practical steps should US government contractors take? Our multidisciplinary team provides an overview of President Trump’s Executive Order 13950, Combating Race and Sex Stereotyping, its labor law implications, potential for litigation, and practical guidance for federal contractors.… Continue Reading
On April 28, 2020, the US Department of Commerce’s Bureau of Industry and Security (BIS) published in the Federal Register a Final Rule amending the Export Administration Regulations (EAR) (15 CFR, subchapter C, parts 730-774) by removing License Exception Civil End Users (CIV) (§ 740.5), which authorized the unlicensed export, reexport, and transfer (in-country) of … Continue Reading
On April 28, 2020, the US Department of Commerce’s 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. This new rule critically expands the licensing requirements for exports, reexports and transfers (in-country) of items subject to the EAR in three … Continue Reading
Effective at 11:59 p.m. EDT on Friday, March 20, 2020 the United States limited non-essential travel across its northern and southern borders through April 20, 2020. The decision comes following negotiations with Canada and Mexico in response to the spread of the Coronavirus Disease 2019 (COVID-19). The restrictions target passengers, not cargo. Administration officials continue … Continue Reading
On October 8, 2019, the Secretary of State announced visa restrictions on Chinese government and Communist Party officials believed to be responsible for, or complicit in, the detention or abuse of Uighurs, Kazakhs or other members of Muslim minority groups in Xinjiang, China. Family members of named persons may also be subject to these restrictions. The visa restrictions support the Department … Continue Reading
In early October, OFAC announced a US$2,718,581 settlement with The General Electric Company (GE) of Boston, Massachusetts. GE, on behalf of three GE subsidiaries, Getsco Technical Services Inc., Bentley Nevada and GE Betz (collectively, the “GE Companies”), agreed to settle its potential civil liability for 289 alleged violations of the Cuban Assets Control Regulations (CACR). Specifically, between December 2010 and February … Continue Reading
Responding to Turkey’s actions in Syria, President Trump issued an Executive Order (EO) blocking property and suspending entry of certain persons contributing to the situation in Syria. Pursuant to the EO, OFAC added three Turkish government officials and two Turkish government agencies, the Ministry of National Defence and the Ministry of Energy and Natural Resources, to the Specially Designated Nationals (SDN) … Continue Reading
On September 4, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) published in the Federal Register a new final rule on the Nicaragua Sanctions Regulations, 31 C.F.R. Part 582 (Nicaragua Regulations), which implement Executive Order (EO) 13851 of November 27, 2018, “Blocking Property of Certain Persons Contributing to the Situation in Nicaragua”. The Nicaragua Regulations mirror the substance … Continue Reading
UPDATE: An annotated form of the full list of covered investment critical infrastructure and functions related to covered investment critical infrastructure as proposed by CFIUS that is referenced below is now available under the CFIUS Resources section of this blog. On September 17, 2019, the US Department of the Treasury issued proposed regulations to implement the … Continue Reading
Russian Counter-sanctions: Bill Introduced to Criminalize Dissemination of Information That May Result in Introduction or Expansion of Sanctions Against Russian Persons Following our recent webinar, our Moscow Team prepared an analysis of a draft Russian legislation that would prohibit media communications that reveal non-compliance with sanctions or facilitate imposition of sanctions and would also impose criminal … Continue Reading
