The Trump Administration has added eight Chinese entities and 36 of their subsidiaries to the US Department of Commerce, Bureau of Industry Security’s (BIS) Entity List. Per the final rule published in the Federal Register on August 2, 2018, “[t]he entities that are being added to the Entity List have been determined by the U.S. Government to be acting contrary … Continue Reading
Our Aerospace & Defense Group is pleased to partner once again with EGADD and Strategic Shipping Company Ltd to host the upcoming “The ITAR ‘Virus’ Continues to EARvolve!” US Export Controls Workshop in Stratford-Upon-Avon, UK, Monday, July 23 – Wednesday, July 25, 2018. 2018 welcomes the 11th anniversary of the workshop.… Continue Reading
BIS published a final rule, effective 20 December 2017, which amended the Export Administration Regulations (EAR) by adding two Russian companies to the Entity List under the destination of Russia on the basis of § 744.11 of the EAR. The added entities are the Joint Stock Company Experimental Design Bureau Novator and the Joint Stock … Continue Reading
Pursuant to the Federal Civil Penalties Inflation Adjustment Act of 1990, as amended by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, the US Commerce Department announced its annual inflationary adjustments to the maximum civil monetary penalties under its jurisdiction. These include, among others, civil monetary penalties issued under the Export Administration … Continue Reading
BIS has published a final rule, effective 1 November 2017, which clarifies two licence exceptions in the Export Administration Regulations (EAR). They are the licence exception for governments, international organisations, international inspections, and the International Space Station (GOV) and for Strategic Trade Authorization (STA). The rule does not change any EAR requirements for the use … Continue Reading
On 6 October, the Trump administration announced that it would permanently revoke economic sanctions against Sudan, effective 12 October 2017. The State Department published this decision in the Federal Register, 82 Fed. Reg. 47287, on 11 October 2017. This decision means that US companies can invest in Sudan and export their products and services to Sudan, subject to compliance with … Continue Reading
Sudan Sanctions In 1997, the US imposed a comprehensive trade and investment embargo against Sudan. In January 2017, i.e., in the closing days of the Obama Administration, President Obama announced a six-month suspension of US economic sanctions, citing ongoing dialogue with the Sudanese government and the government’s progress in achieving milestones agreed upon in those negotiations. Specifically, the Obama Administration … Continue Reading
In June 2017, the Office of Foreign Assets Control (OFAC) and the US Commerce Department’s Bureau of Industry and Security (BIS) imposed coordinated sanctions against two entities from the Crimea Region of Ukraine and eight entities from Russia. OFAC added each entity to the OFAC List of Specially Designated Nationals (SDN List) and Block Persons under the executive orders implemented … Continue Reading
The US Commerce Department’s Bureau of Industry and Security (BIS) has posted long-awaited updates to parts of its website dedicated to guidance on the Export Administration Regulations’ (EAR) encryption controls. The updates implement changes to encryption controls adopted in September 2016, under the Wassenaar Arrangement. Among other things, the new web pages include updated flow … Continue Reading
Effective 18 April 2017, the US Commerce Department, Bureau of Industry and Security (BIS) has revised the Entity List entry for Russia’s Federal Security Service (Federalnaya Sluzhba Bezopasnosti or FSB) to conform to the OFAC general license adopted on 2 February 2017, General License No. 1. That general license authorises transactions otherwise prohibited under Executive … Continue Reading
Effective 19 April 2017, a new rule issued by the Department of Commerce, Bureau of Industry and Security (BIS) will require exporters or re-exporters of certain items subject to the Export Administration Regulations (EAR) to obtain and maintain proof of import or export authorization issued by the government of Hong Kong. Under the rule, persons … Continue Reading
Squire Patton Boggs’ Aerospace, Defense & Government Services Industry Group will co-host the three-day ITAR and EAR workshop sessions, popularly known as “The ITAR Virus EARvolves!“, with EGADD and Strategic Shipping Company Ltd. This year marks the 10th anniversary of these annual workshops, as the ITAR and the EAR continue to evolve. The 2017 conference will … Continue Reading
On 28 December 2016, the US President issued Executive Order (EO) 13757 to amend a 2015 EO authorising the US Treasury Department’s Office of Foreign Assets Control (OFAC) to impose sanctions for significant malicious cyber-enabled activities. Intended to address alleged Russian tampering in the US elections, EO 13575 expands the scope of the 2015 EO … Continue Reading
The US Commerce Department’s Bureau of Industry and Security (BIS) published a final rule implementing changes to the Export Administration Regulations’ (EAR) Short Supply controls on US domestic crude oil. The rulemaking implements changes to the Short Supply controls provisions of the EAR and Commerce Control List (including removing ECCN 1C981) that came into effect in December 2015, under the … Continue Reading
BIS is amending the EAR to reflect changes to the MTCR Annex that were agreed to by MTCR member countries in 2015. The final rule, published in the Federal Register on 4 April 2016, makes conforming changes to correlate the Commerce Control List (CCL) and other EAR provisions with the current MTCR Annex. This includes revisions to six … Continue Reading
